TP Adjustment for AMP Expenditure deleted due to Lack of Brand Promotion Agreement with AE

Kellogg India Pvt. Ltd Vs ACIT (ITAT Mumbai)

ITAT Mumbai held that there was no express arrangement / agreement between the assessee and the AE for incurring advertisement, marketing and promotional expenses (AMP) to promote the brand of the AE and hence the said transactions would not constitute international transaction relating to AMP expenditure. Thus, TP adjustment deleted.

Facts- The Assessee Company claimed to be a wholly owned subsidiary of Kellogg USA and having p

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