Transfer Pricing adjustment of advertisement, marketing and promotion deleted as not an international transaction

Philips India Limited Vs DCIT (ITAT Kolkata) ITAT Kolkata held that the advertisement, marketing and promotion expenses [AMP Expense] not an international transaction and accordingly, the TP adjustment made by Transfer Pricing Officer/ AO is to be deleted. Accordingly, appeal allowed to that extent. Facts- The present appeal has been preferred by the assessee. The transfer priding adjustment of ₹54,41,41,000/- on account of provision of software development services is mainly contested. The issue raised in respect of transfer pricing adjustment of ₹94,41,22,563/- towards alleged advertis...