https://www.taxtmi.com/caselaws?id=286187 The Tribunal found that the Transfer Pricing Officer (TPO) erred in determining the Arm's Length Price (ALP) of a royalty payment at Rs. Nil without proper comparables, solely relying on the benefit test. The Tribunal emphasized that the TPO's jurisdiction is limited to ALP determination and cannot question commercial expediency. The TPO was directed to use the Transactional Net Margin Method (TNMM) and suitable comparables to reevaluate the ALP. The appeal was allowed for statistical purposes, and the case was remitted for a fair reassessment by the TPO/AO. en-us Fri, 15 Feb 2019 00:00:00 +0530 Sun, 16 Feb 2020 08:56:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286187 The Tribunal found that the Transfer Pricing Officer (TPO) erred in determining the Arm's Length Price (ALP) of a royalty payment at Rs. Nil without proper comparables, solely relying on the benefit test. The Tribunal emphasized that the TPO's jurisdiction is limited to ALP determination and cannot question commercial expediency. The TPO was directed to use the Transactional Net Margin Method (TNMM) and suitable comparables to reevaluate the ALP. The appeal was allowed for statistical purposes, and the case was remitted for a fair reassessment by the TPO/AO. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286187