The mere fact that the Assessee was permitted to use the brand name “Valvoline? will not automatically lead to an inference that any expense that the Assessee incurred towards AMP was only to enhance the brand “Valvoline?. The onus was on the Revenue to show the existence of any arrangement or agreement on the basis of which it could be inferred that the AMP expense incurred by the Assessee was not for its own benefit but for the benefit of its AE. That factual foundation has been unable to be laid by the Revenue in the presentcase. On the basis of the existing record, the TPO has found no basis other than by applying the BLT, to discern the existence of international transaction. Therefore, no purpose will be served if the matter is remanded to the TPO, or even the ITAT, for this purpose.