AMP transaction couldn’t be treated as international transaction in absence of any agreement for incurring such exp.

TRANSFER PRICING : Where royalties were paid not only for patent but also for a basket of services and it is not a case of TPO that royalty paid was without any use of brand names and further in TP study, royalty payments were found to be at arm's length, no disallowance could be made

from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000194873/amp-transaction-couldn’t-be-treated-as-international-transaction-in-absence-of-any-agreement-for-incurring-such-exp.aspx