AMP expenditure is not an international transaction

ACIT Vs Mattel Toys (India) Pvt. Ltd. (ITAT Mumbai) Tribunal in assessee’s own case for the A.Yrs.2008-09 and 2009-10  vide order dated 08/07/2016 already held that AMP expenditure is not an international transaction and hence, no ALP adjustment could be made thereon. Respectfully following the aforesaid decision of this Tribunal in assessee’s own case, we hold that the AMP expenditure is not an international transaction and hence no adjustment to ALP need to be made thereon. Accordingly, the grounds raised by the assessee in its cross objections are allowed. FULL TEXT OF THE ITAT JUDGEME...