AMP Expenses Not Separate International Transactions Without Evidence of Inter-Enterprise Transaction

PCIT Vs Wrigley India Pvt. Ltd. (Delhi High Court) Delhi High Court has rejected an appeal filed by the tax authorities challenging a tribunal’s decision that advertising, marketing, and promotional (AMP) expenses incurred by Wrigley India Pvt. Ltd. did not constitute a separate international transaction. The court’s ruling reinforces its earlier pronouncements on the treatment of AMP expenses in transfer pricing assessments, particularly the limited applicability of the Bright Line Test (BLT). The judgment by the High Court concerned the assessment year 2012-13 and arose from an o...