Tribunal held that the Department in the assessee’s case for the AY. 2010-11 onwards had not considered such advertising, marketing and promotion expenses as an international transaction. Further, the expenditure incurred by the assessee on advertisement was revenue in nature since no permanent character or advantage was achieved from it and such expenses for advertising consumer products generally were a part of the process of profit earning and not in the nature of capital outlay. Followed  CIT v. Jubilant Foodworks Pvt. Ltd. [2014 271 ctr 227 (Delhi) (HC) and CIT  v. Monto Motors Ltd. (I. T. A. No. 978 of 2011 dated December 12, 2011 (Delhi)) (HC).(AY. 2007-08, 2008-09)