Amadeus India Pvt. Ltd. v. ACIT (2021) 87 ITR 371 (Delhi)(Trib.)

S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses. [S. 92CA]

The Tribunal l held that the Transfer Pricing Officer had failed to prove that the assessee had incurred the advertisement, marketing and promotion expenses only to benefit the associated enterprise and not to promote its own business. Therefore, the Transfer Pricing Officer had wrongly invoked the provisions of Chapter X of the Act for the advertisement, marketing and promotion expenses incurred. The addition to be deleted. (AY.2014-15)