https://www.taxtmi.com/caselaws?id=470011 Transfer-pricing adjustments for advertisement, marketing and promotion expenditure require independent establishment of an international transaction; the Bright Line Test alone cannot justify an adjustment. The AMP issue is therefore described as requiring fresh consideration in accordance with earlier directions. Royalty adjustments require reasoned examination of functional comparability and the taxpayer's supporting agreements, with a speaking determination. Buying agency services involving procurement assistance, coordination, sourcing and negotiation are characterised as routine commercial agency services rather than managerial, technical or consultancy services. Accordingly, they do not constitute fees for technical services under the applicable domestic-law and treaty provisions, and tax deduction at source is not required, making disallowance under Section 40(a)(i) unwarranted. en-us Tue, 05 Apr 2022 00:00:00 +0530 Mon, 13 Jul 2026 18:47:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470011 Transfer-pricing adjustments for advertisement, marketing and promotion expenditure require independent establishment of an international transaction; the Bright Line Test alone cannot justify an adjustment. The AMP issue is therefore described as requiring fresh consideration in accordance with earlier directions. Royalty adjustments require reasoned examination of functional comparability and the taxpayer's supporting agreements, with a speaking determination. Buying agency services involving procurement assistance, coordination, sourcing and negotiation are characterised as routine commercial agency services rather than managerial, technical or consultancy services. Accordingly, they do not constitute fees for technical services under the applicable domestic-law and treaty provisions, and tax deduction at source is not required, making disallowance under Section 40(a)(i) unwarranted. Case-Laws Income Tax Tue, 05 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470011