https://www.taxtmi.com/caselaws?id=465946 Transfer pricing treatment of Advertisement, Marketing and Promotion (AMP) expenses was examined and the Tribunal found absence of any agreement creating an international transaction for AMP, so no ALP determination for AMP expenses. In the software development segment the assessee's Profit Level Indicator was accepted at 15% (higher than the 35th percentile), therefore no TP adjustment for that segment. For business support services a comparable was excluded due to functional dissimilarity, affecting comparability analysis. Disallowance under general business expense rules for seminars and promotions requires fresh verification and critical evaluation of each expense in light of higher court precedent. en-us Wed, 12 Jul 2023 00:00:00 +0530 Sat, 17 Jan 2026 08:44:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465946 Transfer pricing treatment of Advertisement, Marketing and Promotion (AMP) expenses was examined and the Tribunal found absence of any agreement creating an international transaction for AMP, so no ALP determination for AMP expenses. In the software development segment the assessee's Profit Level Indicator was accepted at 15% (higher than the 35th percentile), therefore no TP adjustment for that segment. For business support services a comparable was excluded due to functional dissimilarity, affecting comparability analysis. Disallowance under general business expense rules for seminars and promotions requires fresh verification and critical evaluation of each expense in light of higher court precedent. Case-Laws Income Tax Wed, 12 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465946