AMP Expenses not qualifies as ‘international transaction’ under Section 92B

Pepsico India Holdings Pvt. Ltd. Vs ACIT (ITAT Delhi)

Conclusion: Addition made on account of AMP expenses qualified as an ‘international transaction’ under the terms of section 92B(1) read with section 92F(v) was not justified as AMP Expenses did not qualify as an ‘international transaction’ for the purposes of section 92B firstly, there was no international transaction in the form of any agreement or arrangement on AMP expenditure incurred by assessee company; and secondly, under FAR an

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