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    <title>Bright Line Test cannot support AMP transfer pricing adjustment; bonus and tax credit issues were remitted for verification</title>
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    <description>Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm&#039;s length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee&#039;s AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.</description>
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    <pubDate>Tue, 21 Apr 2026 17:38:23 +0530</pubDate>
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      <title>Bright Line Test cannot support AMP transfer pricing adjustment; bonus and tax credit issues were remitted for verification</title>
      <link>https://www.taxtmi.com/highlights?id=99009</link>
      <description>Transfer pricing adjustment on AMP expenditure was deleted because the Bright Line Test could not be applied to determine arm&#039;s length price, following Delhi High Court and coordinate Bench precedent; the Tribunal held no adjustment was warranted on the assessee&#039;s AMP spend. The section 43B issue on bonus payment was not decided on merits and was remitted to verify whether the bonus was paid within the return-filing due date, in which case no addition would arise. Claims relating to short grant of self-assessment tax credit and deduction of interest on VAT duty were also restored for fresh examination. The appeal was thus partly allowed.</description>
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