https://www.taxtmi.com/caselaws?id=797083 Transfer-pricing treatment of advertising, marketing and promotion expenditure requires evidence of an arrangement, understanding or concerted action with an associated enterprise; reimbursement alone does not establish an international transaction, and the Bright Line Test or intensity-based benchmarking cannot apply without one. Comparable selection and margin computation must reflect functional similarity, operational income and expenses, foreign-exchange gains linked to operations, working-capital effects and adjustments limited to associated-enterprise transactions. Royalty embedded in an already benchmarked licensed manufacturing segment should not be separately tested under CUP where comparables lack meaningful similarity, as this may duplicate adjustment. Distinct import and support-service transactions may be separately benchmarked where their functional, asset and risk profiles differ; Berry Ratio may be appropriate where goods costs are pass-through costs. en-us Wed, 12 Aug 2026 00:00:00 +0530 Mon, 17 Aug 2026 08:38:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797083 Transfer-pricing treatment of advertising, marketing and promotion expenditure requires evidence of an arrangement, understanding or concerted action with an associated enterprise; reimbursement alone does not establish an international transaction, and the Bright Line Test or intensity-based benchmarking cannot apply without one. Comparable selection and margin computation must reflect functional similarity, operational income and expenses, foreign-exchange gains linked to operations, working-capital effects and adjustments limited to associated-enterprise transactions. Royalty embedded in an already benchmarked licensed manufacturing segment should not be separately tested under CUP where comparables lack meaningful similarity, as this may duplicate adjustment. Distinct import and support-service transactions may be separately benchmarked where their functional, asset and risk profiles differ; Berry Ratio may be appropriate where goods costs are pass-through costs. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797083