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AMP adjustment of ₹4.32 Cr based on Bright Line Test was unsustainable: ITAT Delhi
Case Law Details
- Case Name
- Callaway Golf India Private Limited Vs ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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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...
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