Recently, the Mumbai Bench of the Income-tax Appellate Tribunal (the Tribunal) ruled its decision on the transfer pricing (TP) case of Colgate Palmolive (India) Ltd. v. ACIT (ITA No. 6073/Mum/2014 and ITA No. 2778/Mum/2011) in favor of the taxpayer. The decision concludes that in the absence of an arrangement or agreement with the Associated Enterprise (AE), the taxpayer is not required to undertake any brand building for its AE and there is no “tangible evidence” to substantiate that advertising, marketing, and promotion expenses incurred by the taxpayer led to brand building or to the creation of marketing intangible that benefited the taxpayer group.