https://www.taxtmi.com/highlights?id=101300 AMP expenditure incurred in India for the assessee's own sales and promotion could not be treated as an international transaction merely because it may incidentally benefit the foreign associated enterprise's brand. An agreement, arrangement or understanding between the parties is a condition precedent for transfer pricing adjustment, and higher expenditure or presumed brand-building benefit is insufficient. On that basis, the AMP adjustment was deleted. Consequentially, the AO was directed to allow set off of brought forward business loss and unabsorbed depreciation in accordance with law after giving a reasonable opportunity of being heard. en-us Thu, 02 Jul 2026 08:07:08 +0530 Thu, 02 Jul 2026 08:07:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101300 AMP expenditure incurred in India for the assessee's own sales and promotion could not be treated as an international transaction merely because it may incidentally benefit the foreign associated enterprise's brand. An agreement, arrangement or understanding between the parties is a condition precedent for transfer pricing adjustment, and higher expenditure or presumed brand-building benefit is insufficient. On that basis, the AMP adjustment was deleted. Consequentially, the AO was directed to allow set off of brought forward business loss and unabsorbed depreciation in accordance with law after giving a reasonable opportunity of being heard. Highlights Income Tax Thu, 02 Jul 2026 08:07:08 +0530 https://www.taxtmi.com/highlights?id=101300