Bright Line Test for AMP expense allocation rejected as basis for transfer-pricing; AMP adjustment deleted on appeal

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....Whether the Bright Line Test (BLT) is an appropriate benchmarking method for allocation of advertising, marketing and promotion (AMP) expenses was examined; the tribunal found BLT legally unsustainable as a basis for transfer-pricing adjustment because the AO/TPOs application lacked requisite legal and comparability foundation, and consequently the AMP addition was deleted and the appeal allowed by ITAT.....