https://www.taxtmi.com/caselaws?id=797374 Advertisement, marketing and promotion expenditure incurred for an assessee's own business is not an international transaction merely because an associated enterprise receives an incidental brand-related benefit. A transfer-pricing adjustment requires evidence of an agreement, arrangement or understanding obliging the assessee to incur expenditure for the associated enterprise's brand promotion. In the absence of such evidence or a material factual change from earlier years, the bright line test cannot be used either to infer an international transaction or to compute an adjustment. The proposed adjustment was therefore impermissible and the addition was deleted. en-us Mon, 10 Aug 2026 00:00:00 +0530 Fri, 21 Aug 2026 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797374 Advertisement, marketing and promotion expenditure incurred for an assessee's own business is not an international transaction merely because an associated enterprise receives an incidental brand-related benefit. A transfer-pricing adjustment requires evidence of an agreement, arrangement or understanding obliging the assessee to incur expenditure for the associated enterprise's brand promotion. In the absence of such evidence or a material factual change from earlier years, the bright line test cannot be used either to infer an international transaction or to compute an adjustment. The proposed adjustment was therefore impermissible and the addition was deleted. Case-Laws Income Tax Mon, 10 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797374