International transaction cannot be presumed merely on the basis of Statement of Assessee

Advocate Akhilesh Kumar Sah Renault India Private Limited vs. DCIT (ITAT Chennai) Renault India case: Just because assessee mentioned that marketing expenditure incurred by it helped promotion of Renault brand in India, it cannot be presumed that such expenditure resulted in any international transaction  Recently, in Renault India P. Ltd. vs. DCIT [I.T.A. No. 1078/Mds/2017, A.Y.: 2012-2013, decided on 30.01.2018], one of the ground was assailing of the treatment of advertisement and market promotion activity as an international transaction. Authorised Representative submitted that, by virtu...