https://www.taxtmi.com/caselaws?id=337877 The existence of an international transaction in relation to advertisement, marketing and sales promotion expenditure is a threshold transfer pricing issue that the Tribunal must decide on the material before it. That question cannot be remanded to the Transfer Pricing Officer, DRP or Assessing Officer for determination. Only if the Tribunal first finds that an international transaction exists, and the record is insufficient on arm's length price, may a limited remand on that pricing issue be made. The impugned order was set aside and the matter restored to the Tribunal for fresh decision on the threshold question. en-us Wed, 27 Jul 2016 00:00:00 +0530 Thu, 19 Jan 2017 18:10:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=337877 The existence of an international transaction in relation to advertisement, marketing and sales promotion expenditure is a threshold transfer pricing issue that the Tribunal must decide on the material before it. That question cannot be remanded to the Transfer Pricing Officer, DRP or Assessing Officer for determination. Only if the Tribunal first finds that an international transaction exists, and the record is insufficient on arm's length price, may a limited remand on that pricing issue be made. The impugned order was set aside and the matter restored to the Tribunal for fresh decision on the threshold question. Case-Laws Income Tax Wed, 27 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=337877