Presumption of existence of an international transaction not allowed in transfer pricing provision

Brief of the Case

Delhi High Court held In the case of Maruti Suzuki India Ltd. (MSIL) vs. CIT that the transfer pricing adjustment is not expected to be made by deducing from the difference between the ‘excessive’ advertisement, marketing and sales promotion (AMP) expenditure incurred by the Assessee and the AMP expenditure of a comparable entity that an international transaction exists and then proceed to make the adjustment of the difference in order to determine the value of such

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