Advertisement, Marketing and Promotion expenditure incurred not constitute an “international transaction” u/s 92F of Income Tax Act: Delhi HC

The Delhi High Court ruled that advertisement, marketing, and promotion expenditure incurred by an assessee does not constitute an "international transaction" under Section 92F of the Income Tax Act. The court reasoned that such expenses are typically unilateral in nature and do not involve any cross-border transaction with associated enterprises, which is a prerequisite for them to be classified as international transactions subject to transfer pricing regulations. This ruling provides clarity on the scope of international transactions under Indian tax law.