https://www.taxtmi.com/caselaws?id=338420 In transfer pricing matters, the arm's length price of an international transaction must be determined on the statutory parameters of the most appropriate method and comparable selection. The Transfer Pricing Officer cannot fix reimbursement of advertisement expenses at nil on an ad hoc basis when the assessee has applied the Transaction Net Margin Method and the selected method and comparables are not disputed. The officer's role is confined to transfer pricing analysis under Chapter X and does not extend to testing the allowability or genuineness of expenditure under section 37, which falls within the Assessing Officer's domain. The nil valuation was therefore unsustainable and the issue was decided for the assessee. en-us Mon, 23 Jan 2017 00:00:00 +0530 Wed, 24 Jun 2026 10:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=338420 In transfer pricing matters, the arm's length price of an international transaction must be determined on the statutory parameters of the most appropriate method and comparable selection. The Transfer Pricing Officer cannot fix reimbursement of advertisement expenses at nil on an ad hoc basis when the assessee has applied the Transaction Net Margin Method and the selected method and comparables are not disputed. The officer's role is confined to transfer pricing analysis under Chapter X and does not extend to testing the allowability or genuineness of expenditure under section 37, which falls within the Assessing Officer's domain. The nil valuation was therefore unsustainable and the issue was decided for the assessee. Case-Laws Income Tax Mon, 23 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=338420