Court held that the Tribunal was not justified in remanding the matter to the Assessing Officer/Transfer Pricing Officer for determining the arm’s length price of the advertising, marketing and publicity expenses when the Department had failed to prove that there had existed an international transaction between the assessee and its associated enterprise.(AY.2011-12)
PCIT v. Valvoline Cummins Pvt. Ltd. (2020) 424 ITR 162 (Delhi)(HC)
S.92C:Transfer pricing- Arm’s length price —Appellate Tribunal- Advertising, marketing and publicity expenses —Remand by the Tribunal for determination of arm’s length price is held to be not warranted. [ S.254(1) ]