https://www.taxtmi.com/caselaws?id=789054 AMP expenditure cannot be treated as an international transaction, and the bright line test cannot by itself sustain a transfer pricing adjustment without material showing an arrangement with the associated enterprise; the AMP adjustment was therefore deleted. Daughter marriage fund expenditure was treated as a business-related employee welfare claim requiring verification, so the matter was remitted. Foreign tax credit was restored for factual verification from certificates and reconciliation. The warranty-related unwinding of discount claim was admitted as an additional ground and sent back for fresh examination as an ascertained business liability under the mercantile system. Overall, the appeal was partly allowed, with the principal transfer pricing addition removed and the remaining issues remitted or restored for verification. en-us Mon, 30 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 08:50:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789054 AMP expenditure cannot be treated as an international transaction, and the bright line test cannot by itself sustain a transfer pricing adjustment without material showing an arrangement with the associated enterprise; the AMP adjustment was therefore deleted. Daughter marriage fund expenditure was treated as a business-related employee welfare claim requiring verification, so the matter was remitted. Foreign tax credit was restored for factual verification from certificates and reconciliation. The warranty-related unwinding of discount claim was admitted as an additional ground and sent back for fresh examination as an ascertained business liability under the mercantile system. Overall, the appeal was partly allowed, with the principal transfer pricing addition removed and the remaining issues remitted or restored for verification. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789054