Held that as regards advertisement, marketing and promotion expenses  there is no agreement between assessee and its Associated Enterprise mandating incurring of  advertisement, marketing and promotion expenses. Transfer pricing adjustment is  not warranted.  As regards  reimbursement of  expenses,claim of the  assessee that it had derived tangible benefit from expenditure not substantiated with evidence —Transfer pricing adjustment Sustainable. As regards  royalty   onus to prove that expenses incurred by associated enterprise towards sale of  products and not for purpose of  creating brand awareness not discharged by assessee. Agreement, if any for reimbursing expenses, reserve Bank of  India approval, business necessity or  expediency in making payment, basis of  calculation not furnished. Transfer Pricing adjustment in respect of  third party royalty sustainable. (AY.2016-17)