No Evidence, No AMP Transaction: ITAT Quashes Bright Line Theory Restores LG’s TP Results

LG Electronics India Pvt. Ltd Vs ACIT (ITAT Delhi) This consolidated ITAT Delhi order covers multiple years of LG Electronics India Pvt. Ltd. &  examines three recurring transfer pricing issues—AMP expenses, royalty payments, &  management/HQ service charges. The TPO had treated AMP expenditure as a separate international transaction &  applied the Bright Line Test to make huge TP adjustments. The Tribunal noted that in LG’s own earlier years, &  as per binding Delhi High Court decisions in Sony Ericsson, Maruti Suzuki & others, AMP cannot be presumed as an internat...