2017 (8) TMI 191 - HC - Income Tax

AMP expenses - International transaction between the Assessee and its AE - Held that:- This Court is of the view that the ITAT was not justified in remanding the matter to the AO/TPO for determining the ALP of the alleged international transaction involving AMP expenses, when in fact, the Revenue was unable to show that there existed an international transaction between the Assessee and its AE in the first place.- Decided in favour of the Assessee