Assessee-company was engaged in trading and manufacturing of soft drink beverages, aerated and non-aerated drinks and snacks food items TPO made additions on account of Advertisement, Marketing and Promotional (AMP) expenses determining ALP of said transactions. On appeal the Tribunal held that said AEs had not carried out any function in India and also had not assumed any risk and, further, even for license for use of trademark, no royalty was paid by assessee to its AEs; hence, no benefit accrued to said AEs. Accordingly the addition was directed to be deleted.  (AY. 2015-16)