https://www.taxtmi.com/caselaws?id=802400 Section 92B requires an international transaction to be established before advertising, marketing and promotion expenditure can be subjected to a transfer pricing adjustment. The Revenue must establish an agreement, arrangement or understanding with the associated enterprise; expenditure comparisons or incidental benefits alone do not suffice. The bright line test is not a prescribed method for determining the arm's length price. Reallocated management support costs included in a cost-plus charge must be considered alongside the corresponding service revenue. Section 92(3) restricts the application of transfer pricing provisions where the resulting computation would reduce income chargeable to tax. en-us Wed, 14 Oct 2026 00:00:00 +0530 Thu, 05 Nov 2026 07:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802400 Section 92B requires an international transaction to be established before advertising, marketing and promotion expenditure can be subjected to a transfer pricing adjustment. The Revenue must establish an agreement, arrangement or understanding with the associated enterprise; expenditure comparisons or incidental benefits alone do not suffice. The bright line test is not a prescribed method for determining the arm's length price. Reallocated management support costs included in a cost-plus charge must be considered alongside the corresponding service revenue. Section 92(3) restricts the application of transfer pricing provisions where the resulting computation would reduce income chargeable to tax. Case-Laws Income Tax Wed, 14 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802400