Assessee company is a wholly owned subsidiary of Kellog  USA and had principal activity of manufacturing and selling of breakfast cereal products. The TPO made an adjustment to the income of the assessee on account of AMP expenditure incurred in India  On appeal the Tribunal held that  in view of decision in assessee’s own case for earlier assessment years, since apart from being a distributor of products manufactured by its AE, assessee manufactured its own products in India under license from AE, AMP expenditure incurred by assessee in India to promote brand would not constitute international transaction requiring any TP adjustment. (AY. 2018-19)