Transfer pricing adjustment on AMP spend deleted where no arrangement showed an international transaction with the associated enterprise.

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....In the absence of any agreement, arrangement or understanding showing that AMP expenditure was incurred for the associated enterprise's sole benefit, Chapter X could not be invoked and the transfer pricing adjustment on AMP spend was deleted. The Tribunal treated the section 14A grounds as consequential and accepted them accordingly. It also allowed the ground on computation-sheet mistakes and directed the Assessing Officer to correct the computation errors in accordance with law.....