https://www.taxtmi.com/caselaws?id=799696 Advertisement, marketing and promotion expenditure paid to third parties does not constitute an international transaction merely because it may benefit an associated enterprise. A transfer-pricing adjustment under Chapter X requires the Revenue to establish an agreement, arrangement, or understanding between associated enterprises concerning the AMP expenditure. The bright line test cannot replace proof of an underlying international transaction. In the absence of such evidence, AMP expenditure is outside transfer-pricing adjustment and no arm's-length-price determination is permissible. en-us Fri, 18 Sep 2026 00:00:00 +0530 Fri, 25 Sep 2026 08:16:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799696 Advertisement, marketing and promotion expenditure paid to third parties does not constitute an international transaction merely because it may benefit an associated enterprise. A transfer-pricing adjustment under Chapter X requires the Revenue to establish an agreement, arrangement, or understanding between associated enterprises concerning the AMP expenditure. The bright line test cannot replace proof of an underlying international transaction. In the absence of such evidence, AMP expenditure is outside transfer-pricing adjustment and no arm's-length-price determination is permissible. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799696