Determine existence of international transaction between Assessee & its AE involving AMP expenses: HC to TPO

PCIT Vs Yum Restaurants India Pvt. Ltd (Delhi High Court) The Court sets aside the impugned order and the corresponding orders of the AO/TPO and the DRP as regards the issue of AMP expenses and remands the issue concerning the determination of the existence of an international transaction between the Assessee and its AE involving AMP expenses and the further question of determination of its ALP to the AO /TPO for a fresh decision in light of the judgment of this Court in Sony Ericsson Mobile Communication India P. Ltd. (supra). FULL TEXT OF THE HIGH COURT ORDER /JUDGEMENT 1. The appeal has bee...