https://www.taxtmi.com/caselaws?id=467560 Advertising, marketing and promotion expenditure could not be treated as an international transaction for transfer pricing purposes without tangible material showing an arrangement, understanding, or concerted action for the associated enterprise's benefit, so the AMP adjustment was unsustainable. Royalty on brand and marketing rights was accepted as arm's length on the CUP basis, while technical know-how royalty and management service fee required fresh examination because the factual foundation was incomplete. Interest on receivables did not warrant a separate adjustment where working capital adjustment already captured the credit-period effect. A scientifically estimated warranty provision based on historical claims was allowable as an ascertained liability. Duty drawback and dividend distribution tax issues were remanded for verification. en-us Thu, 17 Apr 2025 00:00:00 +0530 Mon, 23 Mar 2026 17:21:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467560 Advertising, marketing and promotion expenditure could not be treated as an international transaction for transfer pricing purposes without tangible material showing an arrangement, understanding, or concerted action for the associated enterprise's benefit, so the AMP adjustment was unsustainable. Royalty on brand and marketing rights was accepted as arm's length on the CUP basis, while technical know-how royalty and management service fee required fresh examination because the factual foundation was incomplete. Interest on receivables did not warrant a separate adjustment where working capital adjustment already captured the credit-period effect. A scientifically estimated warranty provision based on historical claims was allowable as an ascertained liability. Duty drawback and dividend distribution tax issues were remanded for verification. Case-Laws Income Tax Thu, 17 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467560