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    <description>Advertisement, marketing and promotion expenditure could not be characterised as an international transaction for transfer pricing purposes in the absence of any agreement, arrangement or understanding with the associated enterprise to share or incur such spend for its benefit; the Chapter X adjustment was therefore deleted. The section 14A disallowance was not independently sustained and was accepted in favour of the assessee. Computation mistakes in the assessment order were found to require correction, and the Assessing Officer was directed to amend the computation in accordance with law.</description>
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