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TP additions to be deleted if TPO failed to prove existence of international transaction involving AMP exp.

May 4, 2020[2020] 116 taxmann.com 369 (Delhi - Trib.)
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TRANSFER PRICING: Where TPO made addition to assessee's ALP on ground that assessee should have been compensated by AE at cost plus mark up of 7.19 per cent for undertaking AMP expenses purely for AE, in view of fact that revenue authorities had not been able to prove existence of an international transaction involving AMP expenses between assessee and its AE, impugned addition was to be deleted

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