https://www.taxtmi.com/caselaws?id=787223 Transfer pricing treatment of advertising, marketing and promotion expenses is addressed through the validity of the Bright Line Test, Cost Plus Method and adjusted TNMM for a distributor. The Bright Line Test is legally unsustainable for treating AMP expenditure as a separate international transaction, so BLT-based additions are deleted. Cost Plus treatment is not justified where AMP expenditure relates to trading operations and the record does not support segregating all AMP expenditure as an international service; the addition cannot exceed actual AMP expense or disregard trading reality. Adjusted TNMM may apply on an aggregate basis, with the ALP adjustment limited to the gap between the comparable adjusted margin and the tested party's margin. en-us Wed, 25 Feb 2026 00:00:00 +0530 Sat, 28 Feb 2026 08:41:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787223 Transfer pricing treatment of advertising, marketing and promotion expenses is addressed through the validity of the Bright Line Test, Cost Plus Method and adjusted TNMM for a distributor. The Bright Line Test is legally unsustainable for treating AMP expenditure as a separate international transaction, so BLT-based additions are deleted. Cost Plus treatment is not justified where AMP expenditure relates to trading operations and the record does not support segregating all AMP expenditure as an international service; the addition cannot exceed actual AMP expense or disregard trading reality. Adjusted TNMM may apply on an aggregate basis, with the ALP adjustment limited to the gap between the comparable adjusted margin and the tested party's margin. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787223