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1. TPA - determination of ALP - TP adjustment by applying Bright Line Test (BLT) is not sustainable on protective basis having no statutory mandate.

2. 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...

3. TP Adjustment - MAM - adjustment made towards the AMP expenses by adopting an approach similar to bright line test - if the net profit margin meets the Arm's length...

4. TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses,...

5. TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

6. TP adjustments towards AMP expenditure pertaining to trading segment AND reimbursement of warranty expenses to AE - the AMP expenses and warranty expenses cannot be...

7. This case pertains to a transfer pricing (TP) adjustment dispute involving the selection of the most appropriate method - Resale Price Method (RPM) or Transactional Net...

8. TP Adjustment - Disallowance of non-operating and non-allocable expenses incurred for exploring new business in the line of Maintenance and Operations of Transportation...

9. TP Adjustment - AMP adjustment - Assessee has already been remunerated for the marketing expenses incurred on behalf of the AEs along with commission markup, and,...

10. TP Adjustment - adjustment on account of AMP - we cannot infer the existence of international transactions qua AMP expenses between taxpayer and AE beyond the...

11. TP Adjustment - adjustment made on account of advertisement, marketing and promotion (AMP) expenses - internatinal transaction - the AMP expenditure incurred by the...

12. TP Adjustment - Recovery of expenses represent expenses incurred by the assessee company on behalf of AE towards Bid bond expenses. These expenses were also recovered by...

13. Transfer Pricing Adjustment - adjustment against AMP expenditure - Bright Line Test (BLT) - BLT method as adopted by Ld. TPO was not a valid method to benchmark the...

14. TP Adjustment - apportioning the expenses of assessee’s affiliates - Also noted that the assessee has received certain services from its AE which has been treated by the...

15. The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...