Advertisement expenditure as brand-promotion service requires proof of an arrangement; adjustment deleted and other tax computations remanded.

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....Advertisement and publicity expenditure paid to third-party vendors does not constitute a separate international transaction of brand-promotion services merely because group communication standards exist or an associated enterprise obtains an incidental benefit; an underlying arrangement or understanding must be established. The related transfer-pricing adjustment was deleted. Where an assessment order and computation sheet show differing carry-forward loss figures, the eligible loss requires verification against assessed income or loss and applicable law; limited recomputation was remanded. TDS/TCS credit after amalgamation depends on the transferee offering or being assessed on the corresponding income, subject to verification of amalgamation records, tax credit and supporting evidence; that claim was remanded.....