https://www.taxtmi.com/caselaws?id=302533 The Tribunal allowed the appeal, directing the AO to re-examine the transfer pricing adjustment of Rs. 1,89,53,444 made by the appellant to its AE, as the TPO exceeded his power by determining that the appellant did not receive services and failed the benefit test. The Tribunal emphasized that the determination of whether the payment for services is a business expenditure falls under the AO's jurisdiction, not the TPO's. The matter was remanded for fresh consideration, providing the appellant with an opportunity to present its case. en-us Wed, 04 May 2016 00:00:00 +0530 Fri, 03 Jun 2022 08:26:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=302533 The Tribunal allowed the appeal, directing the AO to re-examine the transfer pricing adjustment of Rs. 1,89,53,444 made by the appellant to its AE, as the TPO exceeded his power by determining that the appellant did not receive services and failed the benefit test. The Tribunal emphasized that the determination of whether the payment for services is a business expenditure falls under the AO's jurisdiction, not the TPO's. The matter was remanded for fresh consideration, providing the appellant with an opportunity to present its case. Case-Laws Income Tax Wed, 04 May 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=302533