ORDER

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J. (Oral)

1. This appeal concerns Assessment Year (AY) 2012-13.

2. Via this appeal, the appellant/revenue seeks to assail the order of Income Tax Appellate Tribunal [in short, "Tribunal"] dated 06.10.2020.

3. The central issue which arises for consideration in the present appeal is: whether Advertising, Marketing and Promotion (AMP) Expenses can be construed as an international transaction, in the facts and circumstances of the present case?

4. The Transfer Pricing Officer (TPO), in this case, seems to have applied the Bright Line Test (BLT). The Tribunal has disagreed with the view of the TPO and, in coming to this conclusion, has relied upon its decision rendered qua the respondent/assessee for AY 2011-12.

5. We had called upon Mr Ruchir Bhatia, learned senior standing counsel, who appears on behalf of the appellant/revenue, to ascertain as to whether any appeal has been preferred qua the decision rendered by the Tribunal qua AY 2011-12.

5.1. Mr Bhatia says that he has received "verbal instructions" that approval was granted for lodging an appeal in this court. However, what is not clear is as to whether,