No AMP expenditure of assessee lead to promotion of brands of its AEs

Pernod Ricard India Pvt. Ltd. Vs DCIT (ITAT Delhi) Conclusion: AMP expenditure of assessee did not have a direct bearing on the promotion of brands of its AEs as the issue stood decided in favour of assessee by the decision of the Tribunal in assessee’s own case for the preceding assessment years i.e., A.Y. 2007-08 and 2008-09. Held: Assessee was a company engaged in the business of manufacture and trading of Indian made foreign liquor (IMFL). Since assessee had entered into certain international transactions, AO made a reference u/s 92CA(1) to the TPO for determination of the ALP of the int...