Case Challenges Transfer Pricing Adjustments for AMP Expenses; Revenue Failed to Prove Arm's Length Price Mechanism or Agreement.

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....TP Adjustment - excessive AMP expenses - third party also benefits - Revenue also could not demonstrate the presence of any machinery provision to compute Arm’s Length Price nor could demonstrate existence of any agreement between the assessee and its AE that the expenses on AMP was incurred for enhancing the brand value of the AE. That, even the bright line method cannot be used either to determine the existence of international transaction or ALP of international transaction. - AT....