Shareholding of . Renault S.A.S France in. RNAIPL was only 30% and balance 70% was held by. Nissan Motor Company Ltd, Japan. Accordingly  influence that could be exerted by . Renault S.A.S France on. RNAIPL was not such that it could freely decide on pricing of latter’s products—M/s. Nissan Motors India Pvt. Ltd was larger shareholder and would not have acceded to such predatory pricing strategy unless it was advantageous to them also. Purchases of cars by assessee from. RNAIPL would not come within meaning of international transaction. Tribunal  also held that no Arm’s  Length Price adjustment could have been carried out on the advertisement and marketing expenditure incurred by the assessee. On the basis of assessee’s mention that marketing expenditure incurred by it helps promotion of Renault brand in India, it cannot be presumed that such expenditure results in any “international transaction. (AY.2012-13)