he moot question involved in the present appeal bearsupon the applicability of the doctrine of mutuality qua theassessee company, a fully owned subsidiary of Yum! Restaurants(India) Pvt. Ltd. (for short, ... “YRIPL”), formerly known as TriconRestaurants India Pvt. Ltd., incorporated for undertaking theactivities relating to Advertising, Marketing and Promotion (forshort, “AMP activities”) for and on behalf of YRIPL and itsfranchisees