Transfer PricingArticle·21 April 2026
Bright Line Test rejected
By J the App
Executive Summary
This decision is a reaffirmation, not innovation, but an important one.
The ITAT decisively reiterates that:
• BLT has no statutory backing
• It stands rejected by jurisdictional High Courts
• Revenue cannot continue applying it merely because appeals are pending
Further, the ruling underscores that AMP expenditure cannot be presumed as an international transaction absent demonstrable arrangement with AE.
Issues for Determination
1. Whether AMP expenditure constitutes an “international transaction” under Chapter X. ...
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