Transfer Pricing Adjustment on AMP Expenses Disallowed Due to Lack of Written Agreement with Associated Enterprise.

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....TP Adjustment - international transaction - in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur AMP expenses, the same cannot be regarded as an international transaction at all. Thus we delete the transfer pricing adjustment made by the TPO on account of AMP expenses incurred by the assessee. - AT....