ITAT deleted Pepsico's AMP adjustment due to absence of agreement with AE to spend on AMP

IT/ILT : There being no arrangement or agreement with AE at any point of time that assessee was required to spend on AMP or it had been done at behest of AE, spending of AMP expenditure by assessee could not be held to be an international transaction between assessee and its AE and accordingly AMP adjustment made by TPO/Assessing Officer would not be sustainable

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