Tribunal held, that advertisement, marketing and promotion expenses did not constitute an international transaction. The arm’s length price adjustment made in this respect is deleted. That the Tribunal in the assessee’s own case for the preceding two years had held in favour of the assessee. The payment of royalty on the import of goods by the assessee from its associated enterprises was governed by the licence agreement which was effective since the year 2005. There was no legal bar on the commercial terms arranged by the assessee in respect of payment of royalty of the net sales. The Special Valuation Branch of the Customs Department had given a categorical finding that royalty was not included in the invoice value of the goods imported by the assessee. While arriving at his conclusion, the Transfer Pricing Officer had nowhere recorded or referred to any material which could demonstrate that royalty payment by the assessee was embedded in the process of the imported goods. It was merely a presumption which could not be upheld looking to the facts of the case and corroborative material placed on record. The upward adjustment in respect of payment of royalty was to be deleted. As regards  to  Information Technology support services, export of  raw material and finished goods,  details of  expenses with debit notes supporting invoices,system up grade.  Distributing dividend to non-Resident shareholders is Matter remanded.  (AY. 2012-13)