International AMP Expenses Confirmed as Transaction with AEs u/s 92B, Affirmed by TPO, DRP, and AO.

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....TP Adjustment - existence of international transaction of AMP Expenses - the revenue has also substantially proved the onus of existence of international transaction between assessee and its AE’s as defined u/s 92B of the Act. Ergo, we are of the opinion that, the TPO/DRP/AO are right in holding the existence of international transaction in the AMP undertaken by the Assessee. - AT....