Can arm’s length price of AMP expenditure be determined by applying the Bright Line Test method?

Last updated: 07 August 2021

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This Income Tax Appellate Tribunal case examines whether the Bright Line Test (BLT) can be used to determine the arm's length price of Advertisement, Marketing, and Promotion (AMP) expenditure. The Tribunal upheld the CIT(A)'s decision, effectively dismissing the Revenue's appeal regarding the deletion of transfer pricing adjustments made on account of AMP expenses. The ruling also addressed other grounds concerning product development and royalty expenditure, dismissing these as well.

Court :
ITAT Mumbai

Brief :
The assessee to explain why the arm’s length price (ALP) of the AMP expenditure should not be determined by applying the Bright Line Test (BLT) method.

Citation :
ITA No.4576/Mum/2019

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Attached File : 1442821_4087_1627024156_ita_no_4576_2019_kellogg_india_pvt_ltd_.pdf

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Judgement posted by

Poojitha Raam Vinay

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I simplify complex income tax, TDS, banking, and investment updates into practical insights for taxpayers, salaried professionals, pensioners, and senior citizens. I regularly write on ITR filing, tax compliance, savings schemes, and the latest financial rule changes in India.

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