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ITAT allowed the appeal of the assessee, setting aside the transfer pricing adjustment in respect of Advertisement, Marketing and Promotion (AMP) expenditures. The Tribunal held that the Revenue failed to discharge the onus to demonstrate existence of an international transaction between the assessee and its associated enterprise and that, absent a contractual or statutory machinery for recovery, Chapter X provisions could not be invoked to impose a notional TP adjustment. The Tribunal noted consistency with its prior rulings and found no change in the factual matrix; accordingly the disputed TP additions were deleted. With regard to foreign tax credit, the AO was directed to consider the assessee's pending application under section 154 and pass a reasoned order.
ITAT allowed the appeal of the assessee, setting aside the transfer pricing adjustment in respect of Advertisement, Marketing and Promotion (AMP) expenditures. The Tribunal held that the Revenue failed to discharge the onus to demonstrate existence of an international transaction between the assessee and its associated enterprise and that, absent a contractual or statutory machinery for recovery, Chapter X provisions could not be invoked to impose a notional TP adjustment. The Tribunal noted consistency with its prior rulings and found no change in the factual matrix; accordingly the disputed TP additions were deleted. With regard to foreign tax credit, the AO was directed to consider the assessee's pending application under section 154 and pass a reasoned order.
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