Tribunal held that Advertising Marketing and Promotion (AMP) expenses is not an international transaction following the order for the AY. 2010-11 (I.T.A./1600/Mum/2015 dtd.17.01.2018) wherein it had held that AMP is not an international transaction as there was no ‘prior arrangement’. (AY. 2011-12)
India Medtronic Pvt. Ltd. v. DCIT (2018) 64 ITR 9 (SN)/ 95 taxmann.com 21 (Mum) (Trib.)
S. 92B : Transfer pricing–International Transaction–Advertising Marketing and Promotion (AMP) expenses is not an international transaction- Adjustment is held to be not justified. [S. 92C]