Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by...

Transfer pricing adjustment made to alleged international transaction of AMP expenditure incurred by assessee disallowed due to lack of evidence that assessee agreed to incur such expenditure on behalf of parent company or that advertising and marketing budget was determined by parent entity. TP adjustments to arm's length price of international transactions in Trading segment under TNMM by altering set of comparable companies upheld as deselection of functionally dissimilar companies justified. Similarly, TP adjustments in Networking segment upheld. TPO directed to grant working capital adjustment and correctly compute profit margins of comparables by excluding non-operational items while determining arm's length price in Trading, Networki..... .....

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