Friday, 4 April 2014

TPO isn't supposed to test business expediency of 'royalty' paid to AE along with its ALP benchmarki

IT/ILT : In transfer pricing proceedings, TPO could not sit in judgment on business and commercial expediency of assessee - company so as to conclude that payment of royalty made by assesse to its AE was unreasonable and, thus, ALP of said payment was to be taken as nil


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