Section 92B of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price — In the absence of any agreement with the associated enterprises for incurring of advertisement, marketing and promotional expenditure and the expenditure having been incurred for payment to third parties in India, it could not be termed as international transaction within the meaning of section 92B. No adjustment for determination of arms length price with regard to advertisement,  marketing and promotional expenditure could be made by resorting to the bright line test or any other similar method which was not provided in the statute — Johnson and Johnson P. Ltd. vs. Additional Commissioner of Income tax [2018] 68 ITR trib 88 (Mumbai)