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“AMP expenditure”

Transfer PricingSection 92CSection 92C149 judgments

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

In the result, appeal filed by the assessee stands partly allowed

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

Private Limited submissions of the assessee in respect of the international transaction proposed an adjustment of Rs.6,85,66,040/- in respect of the AMP expenditure. Thereafter, the Ld. AO while passing the draft assessment order further made disallowance u/s 37 of the Act amounting to Rs.59

UNILEVER INDIA EXPORTS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE - 5(2), MUMBAI, MUMBAI

In the result, both the appeals of the assessee for Assessment Years 2015–16 and 2016–17 are allowed

ITA 4157/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Feb 2026AY 2016-17

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokar & Unilever India Dcit Central Exports Limited, Circle-5(2), Unilever House, B. D. Vs. Room No. 427, 4Th Sawant Marg, Floor, Kautilya Chakala, Andheri Bhawan, C-41 To C- East, Sahar P & T 43, G Block, Bandra Colony, S. O. Kurla Complex, Mumbai-400 099 Bandra (East), Mumbai- 400 051. Pan/Gir No. Aaaci0991D (Applicant) (Respondent) Assessee By Ms. Karishma Phatarphekara/W Shri Harsh Shah & Shri Shreyas Sardesai, Ld. Ars Revenue By Shri Pankaj Kumar, Ld. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 12.02.2026

Section 143(3)Section 144C(13)Section 144C(5)Section 254

assessee undertook a structured and scientific search process: - Databases used: Prowess and CapitalinePlus - Manufacturing sales > 75% - Positive net worth filter - Minimum sales threshold - AMP expenditure filter (< 3%) - R&D expenditure filter (< 3%) 57. The rationale for AMP and R&D filters has been clearly explained in the submissions, namely that ... proposed entrepreneurial FMCG entities with margins ranging from 20.12% to 23.87%, which are clearly full-fledged brand-owning manufacturers incurring substantial R&D and AMP expenditure. These cannot be compared to a limited-risk contract manufacturer.This reinforces that the benchmarking exercise of the assessee was aligned with its functional profile

UNILEVER INDIA EXPORTS LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME-TAX CENTRAL CIRCLE - 5(2), MUMBAI, MUMBAI

ITA 4156/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Feb 2026AY 2015-16
Section 143(3)Section 144C(13)Section 144C(5)Section 254

scientific search process:\n- Databases used: Prowess and CapitalinePlus\n- Manufacturing sales filter > 75%\n- Positive net worth filter\n- Minimum sales threshold\n- AMP expenditure filter (< 3%)\n- R&D expenditure filter (< 3%)\n57. The rationale for AMP and R&D filters has been clearly\nexplained in the submissions ... proposed entrepreneurial\nFMCG entities with charging from 20.12% to 23.87%,\nwhich are clearly full-fledged brand-owning manufacturers\nincurring substantial R&D and AMP expenditure. These cannot\nbe compared to a limited-risk contract manufacturer.This\nreinforces that the benchmarking exercise of the assessee was\naligned with its functional profile, whereas

M/S. BOSE CORPORATION INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

ITA 1596/DEL/2017[2008-09]Status: DisposedITAT Delhi23 Jan 2026AY 2008-09

Bench: Shrivikas Awasthy & Shrisanjay Awasthiआ.अ.सं/.I.T.A Nos.1595 & 1596/Del/2017 िनधा"रणवष"/Assessment Years: 2007-08 & 2008-09 बनाम Bose Corporation India P. Ltd., Acit, Salcon Aurum, 3Rd Floor, Plot No.4, Vs. Circle 5(1), Room No.390, Jasola District Centre, C.R. Building, I.P. Estate, New Delhi. New Delhi. Pan No.Aaacb3260A अपीलाथ" Appellant ""यथ"/Respondent

Section 254

aggrieved by the orders of the Income Tax Appellate Tribunal (ITAT) and urges two questions of law. The first pertains to the AMP expenditure – for which the ITAT has remitted the matter for fresh consideration in the light of its previous Special Bench judgment in L.G. Electronics India ... benchmarked the AMP expenses and made a substantive adjustment of Rs.7,91,74,731/- by adding a gross margin of 50.08% on the entire AMP expenditure incurred by the assessee; and ii) Protective adjustment: The TPO proposed a protective adjustment amounting to Rs.6,47,75,236/- by determining Bright Line

M/S. BOSE CORPORATION INDIA PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, both the appeals of the assessee are allowed

ITA 1595/DEL/2017[2007-08]Status: DisposedITAT Delhi23 Jan 2026AY 2007-08
Section 254

aggrieved by the orders of the Income\nTax Appellate Tribunal (ITAT) and urges two questions of law.\nThe first pertains to the AMP expenditure - for which the ITAT has\nremitted the matter for fresh consideration in the light of its\nprevious Special Bench judgment in L.G. Electronics India ... benchmarked the AMP expenses and\nmade a substantive adjustment of Rs.7,91,74,731/- by adding a gross\nmargin of 50.08% on the entire AMP expenditure incurred by the\nassessee; and\nii) Protective adjustment: The TPO proposed a protective adjustment\namounting to Rs.6,47,75,236/- by determining Bright Line

BROWN- FORMAN WORLDWIDE LLC,GURGAON vs. ACIT, INT, TAXATION, GURGAON

In the result, the appeal of the assessee is partly allowed

ITA 2329/DEL/2022[2009-10]Status: DisposedITAT Delhi21 Jan 2026AY 2009-10
Section 144Section 234BSection 271(1)(c)

fresh search may be\ncarried out to find some new comparables.\n4.1 In order to benchmark the transactions, the undersigned\npropose to compare AMP expenditure of the tested party with\nAMP expenditure of other comparables engaged in similar\nbusiness using Advertisement. and Marketing and Promotional\nexpenditure to the sales ratio

SWATCH GROUP (INDIA) PRIVATE LIMITED,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(2), C.R. BUILDING

In the result, the appeal of the assessee is partly allowed

ITA 5929/DEL/2024[2021-22]Status: DisposedITAT Delhi14 Jan 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2021-22] Swatch Group (India) Private Deputy Commissioner Of Income Limited, Tax, 4Th Floor, Rectangle-I, Plot No. D- Vs Circle 22(2), 4, Saket District Centre, C.R. Building, I.P. Estate, Delhi, New Delhi-110017. 110002. Pan- Aafcs7516R Assessee Revenue

Section 143(3)Section 92C

replies in the matter vide submission dated 19.10.2023, and has raised following issues/points: i. AMP Expenses is not an international Transaction. ii. The AMP expenditure incurred, is only for promoting sales of its products in India / Swatch Group India is not engaged in Brand Building activities. iii. The assessee submitted ... revenue, benchmarking of International transaction for marketing and development of market services for the AE is carried out as under: 16. The ratio of AMP expenditure to sales in the case of the assessee is determined as given below: Sl. Nature of Transactions FY 2020-21 (Amount

ALCON LABORATORIES (INDIA) PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BANGALORE

The appeal are allowed with above direction

ITA 1899/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Jan 2026AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2020-21

For Appellant: Shri Percy Pardiwala, Sr. AdvocateFor Respondent: Shri Aseem Sharma, CIT(DR)(ITAT), Bengaluru
Section 143Section 143(1)(a)Section 144CSection 37Section 40

violation of the guidelines of the Indian Medical Council was upheld. With respect to the determination of the arm's-length price of AMP expenditure were also confirmed. The several comparables objected by the assessee for determination of the arm's-length price of the AMP expenditure was also dismissed ... upheld the selections of comparable as well as upheld the addition with respect to the arm's- length price of the AMP expenditure. With respect to the imputation of interest on outstanding overdue receivable from its AE as per ground No. 5 were also rejected including the markup

DCIT, CENTRAL CIRCLE-20, DELHI vs. LOTUS HERBALS PVT. LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 2445/DEL/2023[2016-17]Status: DisposedITAT Delhi23 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

DCIT vs. Lotus Hearbals Pvt. Ltd. (b) It is not disputed by AO that to build a brand image, any company has to incur AMP expenditure (refer para 12.1); (c) The entire AMP Expenses incurred by the assessee were undisputedly wholly and exclusively incurred for assessee business aspect has been ... owns the brand "LOTUS". LHCC and KC sell their products to the assessee only and do not make any sales to third parties, no AMP expenditure is required to be incurred by the said entities. The assessee owns the brand "LOTUS and thus, AMP expenses are incurred by the assessee

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2444/DEL/2023[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

DCIT vs. Lotus Hearbals Pvt. Ltd. (b) It is not disputed by AO that to build a brand image, any company has to incur AMP expenditure (refer para 12.1); (c) The entire AMP Expenses incurred by the assessee were undisputedly wholly and exclusively incurred for assessee business aspect has been ... owns the brand "LOTUS". LHCC and KC sell their products to the assessee only and do not make any sales to third parties, no AMP expenditure is required to be incurred by the said entities. The assessee owns the brand "LOTUS and thus, AMP expenses are incurred by the assessee

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2443/DEL/2023[2014-15]Status: DisposedITAT Delhi23 Dec 2025AY 2014-15

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

DCIT vs. Lotus Hearbals Pvt. Ltd. (b) It is not disputed by AO that to build a brand image, any company has to incur AMP expenditure (refer para 12.1); (c) The entire AMP Expenses incurred by the assessee were undisputedly wholly and exclusively incurred for assessee business aspect has been ... owns the brand "LOTUS". LHCC and KC sell their products to the assessee only and do not make any sales to third parties, no AMP expenditure is required to be incurred by the said entities. The assessee owns the brand "LOTUS and thus, AMP expenses are incurred by the assessee

DCIT, CC-20, DELHI vs. LOTUS HERBALS PVT. LTD., DELHI

In the result, appeal of the Revenue in appeal No

ITA 2442/DEL/2023[2013-14]Status: DisposedITAT Delhi23 Dec 2025AY 2013-14

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

DCIT vs. Lotus Hearbals Pvt. Ltd. (b) It is not disputed by AO that to build a brand image, any company has to incur AMP expenditure (refer para 12.1); (c) The entire AMP Expenses incurred by the assessee were undisputedly wholly and exclusively incurred for assessee business aspect has been ... owns the brand "LOTUS". LHCC and KC sell their products to the assessee only and do not make any sales to third parties, no AMP expenditure is required to be incurred by the said entities. The assessee owns the brand "LOTUS and thus, AMP expenses are incurred by the assessee

DCIT, CENTRAL CIRCLE-20, NEW DELHI vs. LOTUS HERBALS P.LTD, DELHI

In the result, appeal of the Revenue in appeal No

ITA 200/DEL/2023[2019-20]Status: DisposedITAT Delhi23 Dec 2025AY 2019-20

Bench: Shri Sudhir Kumar & Shri Manish Agarwalita No.2442 To 2445/Del/2023 (Assessment Years 2013-14 To 2016-17) Dcit, Lotus Herbals Pvt. Ltd., Cc-20, Delhi. Room No.269A, 2 Nd Floor, Ara Vs. Centre, E-2, Jhandewalan, New Delhi-110055. Pan-Aaacl0198F (Appellant) (Respondent) Assessee By Shri Rohit Jain, Adv. & Shri Shivam Gupta, Ca Department By Sh. Mukesh Jha, Cit Dr & Ms. Pooja Swroop, Cit-Dr 29.09.2025 Date Of Hearing Date Of Pronouncement 23.12.2025 O R D E R Per Manish Agarwal, Am: These Are Five Appeals Filed By The Revenue Against The Separate Orders Of Learned Commissioner Of Income Tax (Appeals)-27, New Delhi. All Are Dated 12.06.2023 For Assessment Years As Tabulated As Under:

Section 143Section 143(3)Section 147Section 148Section 151

DCIT vs. Lotus Hearbals Pvt. Ltd. (b) It is not disputed by AO that to build a brand image, any company has to incur AMP expenditure (refer para 12.1); (c) The entire AMP Expenses incurred by the assessee were undisputedly wholly and exclusively incurred for assessee business aspect has been ... owns the brand "LOTUS". LHCC and KC sell their products to the assessee only and do not make any sales to third parties, no AMP expenditure is required to be incurred by the said entities. The assessee owns the brand "LOTUS and thus, AMP expenses are incurred by the assessee

ACIT , SPL. RANGE-9, NEW DELHI vs. TIMEX GROUP INDIA LTD., NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 7599/DEL/2019[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Vikas Awasthy& Shri Manish Agarwalआअसं.7527 /िद"ी/2019 (िन.व. 2014-15)

For Appellant: Shri Vikrant A Maheshwari, Advocate (Through VC)For Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 40

assessee is partly allowed. (A.Y. 2014-15) 10. The revenue in appeal has assailed the order of CIT(A) on transfer pricing issues including AMP expenditure only. Both the sides unanimously admitted that all Transfer Pricing issues in the impugned assessment year have been settled under APA. Thus, no dispute

TIMEX GROUP INDIA LTD.,NEW DELHI vs. ADDI. CIT SPL.RANGE-9, NEW DELHI

In the result, appeal of the assessee is partly allowed

ITA 7527/DEL/2019[2014-15]Status: DisposedITAT Delhi28 Nov 2025AY 2014-15

Bench: Shri Vikas Awasthy& Shri Manish Agarwalआअसं.7527 /िद"ी/2019 (िन.व. 2014-15)

For Appellant: Shri Vikrant A Maheshwari, Advocate (Through VC)For Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 40

assessee is partly allowed. (A.Y. 2014-15) 10. The revenue in appeal has assailed the order of CIT(A) on transfer pricing issues including AMP expenditure only. Both the sides unanimously admitted that all Transfer Pricing issues in the impugned assessment year have been settled under APA. Thus, no dispute

AMWAY INDIA ENTERPRISES PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 1(1), DELHI / NFAC, DELHI

Appeal of the assessee is allowed

ITA 5912/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Nov 2025AY 2021-22

Bench: Shri Sudhir Pareek & Shri Manish Agarwalamway India Enterprises Private Dcit, Limited, Circle-1(1), Ground Floor, Elegance Tower, Vs. Delhi/Nfac. Plot No.8, Non Hierarchical Commercial, Jasola, Delhi-110025. Pan-Aaaca5603Q (Appellant) (Respondent)

Section 143(1)(a)Section 143(2)Section 143(3)Section 80GSection 92C

vide its impugned order dated 25.09.2024 has supported the order of the TPO and held that the AMP expenditure claimed by the assessee is international transaction and further observed that the assessee is not a mere distributor of the products of the AE, rather it is providing large number ... AMP is an international transaction in this case transaction in this case 15-16 Quoted section 92B and held Copy Paste quoted AMP expenditure including section 92B and held commission is International AMP expenditure Transaction; including commission is International “It is evident from the above Transaction; extracted provision that arrangement

NETFLIX ENTERTAINMENT SERVICES INDIA LLP,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 23(1), MUMBAI, MUMBAI

In the result, appeal of the assessee is partly\nallowed

ITA 6857/MUM/2024[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22
Section 143(3)Section 144C(5)Section 234ASection 270ASection 40

remotely comparable to that used by\nNetflix India. It also held that the marketing-intensity\nadjustments were defective because the advertisement,\nmarketing, and promotion (AMP) expenditure of Netflix India\nhad not been properly considered, while the comparables\nbeing hardware and software distributors incurred little to no\nAMP expenditure. Consequently

TUPPERWARE INDIA PRIVATE LIMITED,CONNAUGHT PLACE NEW DELHI vs. NATIONAL FACELESS ASSESSMENT CENTRE THROUGH DEPUTY COMMISSIONER OF INCOME TAX, IP ESTATE NEW DELHI

The appeal is allowed partly

ITA 4475/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year : 2020-21

Section 143(3)Section 37Section 92BSection 92C

adhoc basis, thus violating the fundamental principle of transfer pricing; 5.9. computing the amount of adjustment through the application of RPSM by excluding total AMP expenditure and not non-routine expenditure. 5.10. applying BLT to undertake transfer pricing adjustment amounting on protective basis by arbitrarily applying a mark ... amounting to INR 68,27,177, not appreciating that such, adjustment has no statutory mandate. 5.12. including sales and distribution expenses as part of AMP expenditure and ignoring several judicial pronouncements and Ld. DRP’s directions pronounced in Appellant’s own case for AY 2013-14. 6. On the facts

LG ELECTRONICS INDIA PRIVATE LIMITED,MATHURA ROAD, NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 433/DEL/2024[2005-06]Status: DisposedITAT Delhi15 Oct 2025AY 2005-06

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes, he undertook benchmarking analysis of AMP expenditure applied Bright Line Test by comparing ratio of AMP expenditure to the sales of the assessee with that of the comparable companies and held that ... brand/ trade name owned by the AE, requiring suitable compensation from the AE. The ld TPO for applying bright line test compared AMP expenditure incurred by the assessee as percentage of total turnover @9.56% with average AMP expenses of of 3.69% of various comparable companies. The TPO concluded that AMP

LG ELECTRONICS INDIA PRIVATE LIMITED ,NEW DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, DELHI

In the result, the appeal of the revenue in ITA No

ITA 430/DEL/2024[2006-07]Status: DisposedITAT Delhi15 Oct 2025AY 2006-07

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Dharm Veer Singh, CIT(DR)

AMP expenses as an international transaction within the meaning of Section 92B of the Act. For this purposes, he undertook benchmarking analysis of AMP expenditure applied Bright Line Test by comparing ratio of AMP expenditure to the sales of the assessee with that of the comparable companies and held that ... brand/ trade name owned by the AE, requiring suitable compensation from the AE. The ld TPO for applying bright line test compared AMP expenditure incurred by the assessee as percentage of total turnover @9.56% with average AMP expenses of of 3.69% of various comparable companies. The TPO concluded that AMP

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