Section 92B and 92F of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price— Revenue cannot resort to quantity adjustment by determining the AMP expenses spent by the assessee after applying BLT to hold it to be excessive and thereby evidencing the existence of International transaction involving the AE. It would be  very difficult to treat AMP as separate international transaction and any attempt to benchmark such a presumed transaction in any manner would be a very difficult exercise — Casio India Co. P. Ltd. vs. Deputy Commissioner of income tax [2020] 203 TTJ (Delhi) 180