On reporting international transaction more than the prescribed limit of Rs. 15 crore, the assessing officer (AO) made reference to Transfer Pricing Officer (TPO) for computation of Arms Length Price (ALP). During the T.P. assessment proceeding, the TPO noted that the assessee has incurred huge expenses of Rs. 711.57 crore on advertising and marketing and promotion (AMP), and thus creating valuable marketing intangible by incurring huge expenses for L'Orial brand. The assessee is not the legal owner of the brand in India and by way of huge marketing expenses which effectively translate into development of brand and thus contributing the huge expenses for development of brand AEs. On the aforesaid view, the TPO issued show-cause notice as to why the adjustment as undertaken in AY 2014-15 should not be adopted in AY 2015-16. The TPO also took his view that the function performed asset implied and risk assumption (FAR) is materially remains the same.