TP adjustment deleted in absence of written agreement to incur expense between assessee and AE

Nike India Private Limited Vs DCIT (ITAT Bangalore) ITAT Bangalore held that in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur advertisement, marketing and promotion (AMP) expenses, the same cannot be regarded as an international transaction at all and hence TP adjustment not sustainable Facts- During the course of assessment proceedings, the matter was referred to TOP to determine the ALP of the international transaction undertaken by the assessee with its associates. TPO passed the order u/s 92CA proposing adjustment of Rs. 63,27,41...