AMP adjustment of ₹4.32 Cr based on Bright Line Test was unsustainable: ITAT Delhi

Callaway Golf India Private Limited Vs ITO (ITAT Delhi) Conclusion: Bright Line Test (BLT) could not be applied for determining the Arm’s Length Price (ALP) of Advertisement, Marketing, and Promotion (AMP) expenditure under the transfer pricing provisions. Held: Assessee was engaged in the distribution of golf equipment, balls, and accessories in India. For the Assessment Year 2012-13, assessee had disclosed international transactions with its Associated Enterprise (AE) in the area of marketing and distribution of the goods of the assessee. During the transfer pricing proceedings, Transfer P...