https://www.taxtmi.com/highlights?id=102909 Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed. en-us Fri, 21 Aug 2026 08:28:05 +0530 Fri, 21 Aug 2026 08:28:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102909 Advertisement, marketing and promotion expenditure incurred for an assessee's own business and market penetration does not constitute an international transaction merely because an associated enterprise receives an incidental benefit. An agreement or arrangement with the associated enterprise is required to establish such a transaction. The bright line test is not a recognised method for inferring an international transaction or making a transfer pricing adjustment. Applying earlier coordinate-bench decisions on materially identical facts, the AMP transfer pricing adjustment was deleted and the assessee's appeal was allowed. Highlights Income Tax Fri, 21 Aug 2026 08:28:05 +0530 https://www.taxtmi.com/highlights?id=102909