Bright-Line Test Not Applicable for TP Adjustments on Jewellery, Textiles, and Gift Exports, ITAT Remands Joy Alukkas Case for Fresh Benchmarking

The ITAT remanded the transfer pricing case of Joy Alukkas, ruling that the bright-line test is inapplicable for adjustments concerning jewellery, textiles, and gift exports. The Tribunal directed fresh benchmarking, considering the unique business practices and market conditions of these sectors. It emphasized that standard comparability methods may not adequately reflect the operational realities of specialized industries. This decision ensures that arbitrary transfer pricing adjustments are avoided, highlighting the need for nuanced assessment in sector-specific transactions and reinforcing principles of fairness in international taxation.