https://www.taxtmi.com/caselaws?id=468476 AMP expenditure cannot be treated as a separate international transaction absent an explicit arrangement or tangible material showing such transaction with an associated enterprise, and the bright line test was rejected; the transfer pricing adjustment was deleted. Disallowance under section 14A was confined to investments that actually yielded exempt income during the year, because only those investments could enter the average investment computation, and the 2022 Explanation was held prospective; the wider disallowance was restricted. The reversal of inventory provision required fresh verification of whether the underlying provision had already been taxed, so the matter was remanded for examination. en-us Thu, 12 Jan 2023 00:00:00 +0530 Fri, 08 May 2026 12:32:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468476 AMP expenditure cannot be treated as a separate international transaction absent an explicit arrangement or tangible material showing such transaction with an associated enterprise, and the bright line test was rejected; the transfer pricing adjustment was deleted. Disallowance under section 14A was confined to investments that actually yielded exempt income during the year, because only those investments could enter the average investment computation, and the 2022 Explanation was held prospective; the wider disallowance was restricted. The reversal of inventory provision required fresh verification of whether the underlying provision had already been taxed, so the matter was remanded for examination. Case-Laws Income Tax Thu, 12 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468476