Bright-line test for TP adjustment on AMP expenditure is unsustainable in law

Timex Group India Ltd. Vs ACIT (ITAT Delhi) Brief facts of the case are that the assessee is a company engaged in the business of manufacture, trading, sale and servicing of quartz, analogue and digital watches and watch components; manufacture and sale of plastic components, tools and moulds; and rendering information technology and financial support services to its overseas group companies. Recording that the assessee has international transaction with the Associated Enterprises (“AEs”), learned Assessing Officer referred the determination of the Arms Length Price (“ALP”) to the Ld. ...