Tribunal held that the Transfer Pricing Officer had not brought any fact on record to show that there existed any agreement between the assessee and its associated enterprise to share or reimburse the advertising and marketing and promotion expenses. As the Department had failed to discharge the onus that was cast upon it as regards proving that there was an understanding or an arrangement or action in concert under which the assessee had agreed for incurring of advertising and marketing and promotion expenses for brand building of its associated enterprise. Thus no adjustment on account of advertisement and marketing expenses could be made. As regards additional evidence regarding on account of payment for packaging design, cost, training to saloon customers and promotional goods by the assessee to its associated enterprise, which required consideration and verification by the Assessing Officer, the issue was remitted to the Assessing Officer for consideration and decision on the issue afresh. As regards  intangible assets collectively called goodwill, which included various permits, employees, and contracts though the assessee had specifically contended about its claim of goodwill. Considering the facts that neither the Assessing Officer nor the Panel had considered the facts as placed before the Tribunal, the issues were remitted to the Assessing Officer to consider these issues afresh by considering the submission of the assessee and the evidence and pass the order in accordance with law.. As regards  to grant the credit of self-assessment tax and recompute the interest under sections 234A and 234B afresh in accordance with law.(AY. 2015-16)