Advertising and Marketing Promotion Costs Not Considered Separate Transaction Under Transfer Pricing Rules

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....HC determined that AMP expenditure does not constitute a separate international transaction requiring transfer pricing adjustment. The Tribunal consistently applied precedential principles from prior cases, concluding that AMP expenditure cannot be benchmarked as an independent transaction. Consequently, the Transfer Pricing Officer's adjustment was deleted across multiple assessment years. The court affirmed the Tribunal's reasoning, finding no merit in remanding the matter for further investigation. The assessee's appeal was allowed, effectively eliminating the proposed transfer pricing adjustment related to AMP expenditure.....