JUDGMENT

Rajiv Shakdher, J.

Prefatory facts:

1. This appeal concerns Assessment Year (AY) 2007-08. Via the instant appeal, the appellant/revenue seeks to assail the order dated 21.12.2018 passed by the Income Tax Appellate Tribunal [hereafter referred to as "the Tribunal"].

2. Although a perusal of the appeal discloses that three (3) questions are proposed on behalf of the appellant/revenue, in substance, they veer around one (1) issue, which is, whether the reimbursement of advertising, marketing and promotion expenses (AMP), incurred by the respondent/assessee on behalf of its Associated Enterprise (AE), was at arm's length. In other words, whether any upward adjustment was required to be carried out in the amount received by the respondent/assessee from its AE.

2.1. The inter-related issue that arose for consideration was whether the Transfer Pricing Officer (TPO) ought to have used the bright line test (BLT) in computing the arm's length price (ALP) concerning AMP activities carried out by the respondent/assessee.

3. The aforementioned issues arise for consideration against the backdrop of the following broad facts and circumstances.

3.1. In and about November 1994, the respondent/ass