https://www.taxtmi.com/caselaws?id=471239 AMP expenditure cannot be treated as an international transaction merely because it exceeds comparable AMP-to-sales ratios. Where purchase transactions were benchmarked under the Transactional Net Margin Method and Resale Price Method without identified defects, an adjustment based on alleged creation of marketing intangibles requires tangible material showing an arrangement with the associated enterprise. The Bright Line Test is neither a prescribed method nor a mandatory procedure for identifying or benchmarking an AMP transaction under the transfer-pricing framework. Accordingly, the AMP adjustment was unsustainable and the issue was resolved in favour of the assessee. en-us Fri, 14 Jun 2019 00:00:00 +0530 Wed, 26 Aug 2026 12:52:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471239 AMP expenditure cannot be treated as an international transaction merely because it exceeds comparable AMP-to-sales ratios. Where purchase transactions were benchmarked under the Transactional Net Margin Method and Resale Price Method without identified defects, an adjustment based on alleged creation of marketing intangibles requires tangible material showing an arrangement with the associated enterprise. The Bright Line Test is neither a prescribed method nor a mandatory procedure for identifying or benchmarking an AMP transaction under the transfer-pricing framework. Accordingly, the AMP adjustment was unsustainable and the issue was resolved in favour of the assessee. Case-Laws Income Tax Fri, 14 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471239