ITAT Deletes AMP TP Adjustment as No International Transaction Existed

Renault India Pvt. Ltd. Vs DCIT (ITAT Chennai) The Income Tax Appellate Tribunal (ITAT), Chennai partly allowed the assessee’s appeal for Assessment Year 2022-23, holding that advertisement, marketing and promotion (AMP) expenditure incurred in India without any agreement or arrangement with the Associated Enterprise (AE) does not constitute an international transaction for transfer pricing purposes, and directing the Assessing Officer (AO) to allow set-off of brought-forward business losses and unabsorbed depreciation in accordance with law. The assessee, a subsidiary of Renault Group BV, N...