Transfer Pricing Adjustment - adjustment against AMP expenditure ...

Transfer Pricing Officer's Bright Line Test Invalidated in AMP Expenditure Case; Lacks Explicit Assessee-AE Arrangement.

September 10, 2020

Case Laws Income Tax AT

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 transactions. The technical collaboration agreement as referred to by Ld. TPO did not envisage any such express arrangement / agreement between the assessee and its AE and therefore, the same could not support the case of the revenue. - AT

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Transfer Pricing Adjustment - adjustment against AMP expenditure ...

Transfer Pricing Officer's Bright Line Test Invalidated in AMP Expenditure Case; Lacks Explicit Assessee-AE Arrangement.

September 10, 2020

Case Laws Income Tax AT

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