If AMP is an International Transaction than TPO have jurisdiction over it even without any reference by A.O.

Appeal is raised by the assessee against the addition of Rs. 40,64,33,832/- made by Assessing Officer (A.O.) in its order issued u/s 143(3) read with section 144C of the Income Tax Act , 1961 (herein after refer as “the Act”) in relation to A.Yr. 2010-11. Brief of the Case In the case M/s Nikon India (Pvt) Ltd. Vs. DCIT, ITAT held that the AMP (Advertising, Marketing & Promotion) is an international transaction and bright line test cannot be applied on it. Considering the Rule 10 B & relying on the judgment of Honable High Court in Sony Ericsson Mobile Communication Private Limite...