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TP adjustment in respect of AMP expenses be restricted by applying RPM instead of bright line test

September 28, 2020[2020] 119 428 (Delhi - Trib.)

Transfer pricing : Where assessee-company, engaged in distribution of consumer durable products of its A.E. in India, purchased finished goods from its AE which owned intangible rights containing brand name in respect of said goods, the A.O. made addition on account of alleged international transaction resulting from AMP expenses incurred by assessee by applying bright line test, since Bright line test as applied by TPO was not appropriate, said transaction be benchmarked by applying RPM and adjustment be made accordingly

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