AMP Expenditure Not an International Transaction: Delhi HC Reaffirms

PCIT Vs Casio India Company Pvt. Ltd (Delhi High Court) Core Issue: Transfer Pricing adjustment concerning Advertisement, Marketing, and Promotion (AMP) expenses, specifically the application of the Bright Line Test (BLT). Summary of the Legal Challenge The Delhi High Court took up an appeal filed by the Revenue, challenging an order from the Income Tax Appellate Tribunal (ITAT) dated July 19, 2022, which had ruled in favor of the assessee, Casio India Company Pvt. Ltd. The ITAT’s decision effectively deleted a transfer pricing adjustment that the Revenue sought to impose on the assesse...