Brand promotion by ‘Shilpa Shetty’ not an international transaction in absence of pre-requisite agreement

IT/ILT : Where pre-requisite of a prior agreement between a non-AE with AE of an assessee was not fulfilled, transaction between assessee and company to which it provided brand ambassadorship services could not have been regarded as an 'International transaction'

from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000183315/brand-promotion-by-‘shilpa-shetty’-not-an-international-transaction-in-absence-of-pre-requisite-agreement.aspx