There is no evidence to show any kind of agreement existed between the assessee and it’s AE towards reimbursement of AMP the same cannot be treated as an international transaction (AY.2010-11)
Casio India Co. (P) Ltd. v. Dy. CIT (2020) 203 TTJ 180 (Delhi)(Trib.)
S. 92B : Transfer pricing-No evidence to show any kind of agreement existed between the assessee and its AE towards reimbursement of AMP-Cannot be treated as an international transaction. [S. 92C]