Shanti Prime Publication Pvt. Ltd.
Sec. 92C of Income Tax Act, 1961—Transfer Pricing—Computation of arms length price - AMP transaction does not represent the international transaction between the assessee and its AE’s as the revenue failed to bring on record any contract or arrangement between assessee and its AE for making AMP expenses for promotion of brand of its AE, therefore, in the assessee's case, the assessee company was not under any obligation to incur AMP expenses and also its parent company had no control over such decisions of RBIL and these are routine advertisement expenses, thus, AMP cannot be regarded as international transaction - RECKITT BENCKISER (I) PVT. LTD. V/s DEPUTY CIT -  81 ITR (TRIB) 577 (ITAT-KOLKATA)