Section 92B and 92C of the income tax Act, 1961 — Transfer Pricing — Computation of arms length price — The scope and value of the international transaction could not be expanded beyond the reimbursements received under the marketing Development fund agreement to cover the entire gamut of advertisement, marketing and promotion Expenditure incurred by the assessee during the year. Bright line approach was untenable in law either as a way to determine the existence of an International transaction or as a method to determine the arms length price of an International transaction pertaining to advertisement, marketing and promotion and no international transaction can be presumed to exist merely on the basis of the bright line of Expenditure incurred by comparable companies. Reimbursement received by the assessee from its AE for a part of advertising, marketing and promotion Expenditure formed part of the operating income as well as expenditure which went into the Computation of the net profit margin— Samsung India Electronics P. Ltd. vs. Additional Commissioner of income tax [2019] 76 ITR (trib) 145 (Delhi)