Bright Line Test cannot be applied for determining AMP expenses

Whirlpool of India Ltd. Vs DCIT (ITAT Delhi)

Conclusion:  Bright line test is not an appropriate yardstick for determining existence of an international transaction for calculating arm’s length price.

Held: Assessee was a subsidiary of Whirlpool USA, and was engaged in production, sale and distribution of Whirlpool appliances. During the year, assessee incurred advertising, marketing and promotional (AMP) expenses. TPO proposed adjustment on account of AMP expenses by applying

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