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2019 (4) TMI 413 - AT - Income TaxAdjustment on account of AMP expenses - “international transaction” - Bright line Test application - HELD THAT:- As relying on M/S PEPSICO INDIA HOLDINGS PVT LTD, ERSTWHILE M/S PEPSI FOODS PVT. LTD.) VERSUS ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE 1, CHANDIGARH [2018 (12) TMI 277 - ITAT DELHI] reject Bright line Test applied by TPO and further hold that, AMP expenditure cannot be considered as International transaction in the facts and circumstances of present case. - Decided in favour of assessee.
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