Transfer Pricing Adjustment on AMP Expenditure Requires Proof of Benefit to Associated Enterprise's Brand, per Section 92B.

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....TP adjustment on account of AMP expenditure - International transaction u/s 93B - Unless it was shown that there was such an arrangement which resulted into any direct or indirect benefit to the brand of assessee’s AE, these transactions could not be regarded as international transaction u/s 92B - AT....