The Special Bench of the Income Tax Appellate Tribunal (ITAT) issued its decision (held by majority) on 23 January 2013 in the case of L.G. Electronics India Private Limited v. ACIT (ITA No. 5140/Del/2011) that advertising, marketing and promotion (AMP) expenses constitute an "international transaction" and that the bright-line test is an acceptable method for determining the arm's length price (A…