2017 (8) TMI 1484 - AT - Income Tax

TPA - AMP expenses - whether is an international transaction as per the provisions of section 92B of the Act or not? - Held that:- As the issue is covered in favour of assessee, respectfully following Tribunal’s decision in assessee’s own case for AY 2008-09 and 2009-10 [2016 (4) TMI 1146 - ITAT MUMBAI] we also hold that the AMP expenses and transaction arising out of the same is not international transaction and cannot be subject matter of TP adjustment u/s 92C of the Act. - Decided in favour of assessee.