No addition for AMP transactions in absence of International Transaction between Taxpayer & AE

Xerox India Ltd. Vs DCIT (ITAT Delhi) The issue under consideration is whether addition made on account of Advertisement, Marketing, and Sales Promotion (AMP) transactions is justified in law? ITAT states that firstly, there is not an iota of material with ld. TPO to prove the existence of an international transactions involving AMP expenses by the taxpayer. TPO rather proceeded on the premise that the AMP expenditure incurred by the taxpayer were far excess of AMP expenses incurred by the comparables. TPO has also applied the BLT which has been discarded by the Hon’ble High Court in a numbe...