https://www.taxtmi.com/caselaws?id=797682 Advertising, marketing and promotion expenditure constitutes an international transaction under Chapter X only where tangible material establishes an arrangement or understanding requiring expenditure for brand promotion on behalf of associated enterprises, together with its transaction price. The Bright Line Test has no statutory basis to establish either the existence of such a transaction or its arm's length price. Where no such arrangement is established and the assessee's other international transactions are accepted at arm's length, neither a substantive Cost Plus Method adjustment nor a protective Bright Line Test adjustment survives; both adjustments are deleted. en-us Wed, 19 Aug 2026 00:00:00 +0530 Wed, 26 Aug 2026 08:27:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797682 Advertising, marketing and promotion expenditure constitutes an international transaction under Chapter X only where tangible material establishes an arrangement or understanding requiring expenditure for brand promotion on behalf of associated enterprises, together with its transaction price. The Bright Line Test has no statutory basis to establish either the existence of such a transaction or its arm's length price. Where no such arrangement is established and the assessee's other international transactions are accepted at arm's length, neither a substantive Cost Plus Method adjustment nor a protective Bright Line Test adjustment survives; both adjustments are deleted. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797682