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. Con

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