Tribunal held that in the absence of an express arrangement or agreement between the assessee and its associated enterprise for incurring the advertising, marketing and promotion expenditure to promote the brand of the associated enterprise, advertising, marketing and promotion expenditure incurred by making payment to third parties for promoting and marketing the product manufactured by the assessee did not come within the purview of international transaction. (AY. 2013-14)
JCIT v. General Mills India P. Ltd. (2020) 80 ITR 45 (SN) (Mum.)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Advertising, marketing and promotion expenses-Not international transaction-No adjustment can be made. [S. 92CA]