TPO Unable to Prove Assessee's Marketing Expenses Benefited Associated Enterprise u/s 92 of Income Tax Act.

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....TPA - addition of AMP expenses - TPO has failed to prove that the real intention of the assessee in incurring advertisement and marketing expenses were to benefit the AE's. and not to promote its own business. Transferring of profit from India, the basic ingredient to invoke the provisions of section 92 of the Act, remains unproved - AT....