Tribunal held that AMP expenses incurred by MSIL could not be treated and categorised as international transaction under Section 92B of the Act accordingly addition is held tobe not justified. (AY.2008 -09)
Maruti Suzuki India Ltd. v. ACIT (2018) 191 TTJ 148 (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s Length Price—AMP expenses incurred by MSIL could not be treated and categorized as international transaction- No adjustment can be made. [S. 92B]