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ThynkTax /Tax Reference /Case Laws /PepsiCo - brand-building

PepsiCo - brand-building

Income Tax Appellate Tribunal·2021·ITR
Facts

Marketing spend by PepsiCo India for brand-building. TPO sought to add AMP adjustment.

Issue

Bright-line test for AMP.

Held

Bright-line test rejected; AMP is not an inherent international transaction.

Ratio

Following Maruti Suzuki SC - AMP requires proven agreement, not inferred from comparable analysis.

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