Himalaya Drug Company. v. DCIT (2021) 188 ITD 201 (Bang.) (Trib.)

S. 92C : Transfer pricing-Arm’s length price-Advertisement expenses-No agreement between AE-Adjustment was deleted-adjustment of royalty was deleted.

Following the earlier order addition made on account of advertisement expenses was deleted as there was no agreement between the AE and the assessee. Since assessee had not collected any amount over and above selling price either from domestic customers or from non-AEs, said adjustment was to be deleted. (AY. 2014-15)