https://www.taxtmi.com/caselaws?id=795608 Transfer-pricing adjustment for advertising, marketing and promotion expenditure cannot be sustained through the Bright Line Test where binding High Court precedent has rejected that method for determining the arm's length price of AMP-related international transactions. Expenditure exceeding comparable entities' AMP spend cannot, on that basis alone, be treated as incurred to build a foreign associated enterprise's brand. In the absence of a contrary superior-court ruling or a stay, the jurisdictional precedent governs, resulting in deletion of the AMP adjustment. The parties remain subject to the outcome of the pending Supreme Court proceedings. en-us Mon, 20 Jul 2026 00:00:00 +0530 Fri, 24 Jul 2026 08:36:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795608 Transfer-pricing adjustment for advertising, marketing and promotion expenditure cannot be sustained through the Bright Line Test where binding High Court precedent has rejected that method for determining the arm's length price of AMP-related international transactions. Expenditure exceeding comparable entities' AMP spend cannot, on that basis alone, be treated as incurred to build a foreign associated enterprise's brand. In the absence of a contrary superior-court ruling or a stay, the jurisdictional precedent governs, resulting in deletion of the AMP adjustment. The parties remain subject to the outcome of the pending Supreme Court proceedings. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795608