Sec. 92C of income Tax Act, 1961—Transfer Pricing—No adjustment is to be made on account of transfer pricing adjustment of AMP expenses in the hands of the assessee, the case of the Assessing Officer/TPO falls in the absence of any value addition, accordingly, RPM is the most appropriate method to be applied. - MSD PHARMACEUTICALS (P.) LTD. V/s DY. CIT - [2020] 183 ITD 080 (ITAT-DELHI)