Ad and Sales Promotion Costs for Third Parties: Evaluate Under Chapter X, Not Disallowed u/s 37(1.

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....Disallowance of advertisement and sales promotion expenses - if the expenditure is incurred by the assessee for the purposes of the benefit of the third party or its overseas sister concern, it becomes an international transaction which could not have been resulted into disallowance u/s 37 (1) but determination of Arm/s length price of such transaction under Chapter X of The Act. - No additions - AT....