https://www.taxtmi.com/caselaws?id=787223 The note addresses transfer pricing treatment of distributor AMP expenditure, clarifying that the Bright Line Test is legally unsustainable and BLT-based adjustments should be deleted. It states the Cost Plus Method is not appropriate where AMP is incurred in connection with trading operations and cannot be wholly segregated as a separate international service, so Cost Plus adjustments exceeding actual AMP/trading reality must be reduced. It endorses an adjusted TNMM (intensity/aggregate approach) consistent with Sony Ericsson guidance where comparability yields an average adjusted PLI above the tested party, directing an ALP adjustment equal to the margin gap (here 1.36% of net sales) to be computed by the assessing officers. 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 The note addresses transfer pricing treatment of distributor AMP expenditure, clarifying that the Bright Line Test is legally unsustainable and BLT-based adjustments should be deleted. It states the Cost Plus Method is not appropriate where AMP is incurred in connection with trading operations and cannot be wholly segregated as a separate international service, so Cost Plus adjustments exceeding actual AMP/trading reality must be reduced. It endorses an adjusted TNMM (intensity/aggregate approach) consistent with Sony Ericsson guidance where comparability yields an average adjusted PLI above the tested party, directing an ALP adjustment equal to the margin gap (here 1.36% of net sales) to be computed by the assessing officers. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787223