Delhi HC disagrees with Special Bench’s decision in LG’s case; rejects ‘bright line’ test to determi

IT/ILT: Where AO/TPO accepts comparables adopted by assessee, with or without making adjustments, as a bundled transaction, it would be illogical and improper to treat AMP expenses as a separate international transaction - If functions performed by tested parties and the comparables match, with or without adjustments, it would mean that AMP expenses are duly accounted for - It would be odd to accept comparables and determine or accept transfer price and still segregate AMP expenses as an interna