Expense not liable as international transaction in absence of agreement between assessee and AE

DCIT Vs Mattel Toys (India) Pvt. Ltd (ITAT Mumbai) ITAT Mumbai held that as there doesn’t exist any formal/ informal agreement between the assessee and AE to share/ reimburse AMP (Advertising Marketing and Promotion) expenses incurred by the assessee in India. The same cannot be held liable as an international transaction. Facts- The assessee company is incorporated in India. It is an indirectly wholly owned subsidiary of Mattel Inc., USA and is engaged in manufacturing and sales of ‘toys’ products of Mattel ground in India. In the assessment order passed u/s 143(3) r.w.s. 144C(3) of the...