https://www.taxtmi.com/caselaws?id=434388 The Tribunal partly allowed the appeal by the assessee, primarily due to the improper adjustment of the franchise fee payment by the Transfer Pricing Officer (TPO). The TPO's jurisdiction was emphasized to be limited to determining the Arm's Length Price (ALP) without questioning the necessity of the expenditure. The Tribunal rejected the application of the benefit test by the TPO and dismissed other grounds related to penalty proceedings and interest charges. en-us Thu, 22 Sep 2022 00:00:00 +0530 Wed, 22 Feb 2023 11:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434388 The Tribunal partly allowed the appeal by the assessee, primarily due to the improper adjustment of the franchise fee payment by the Transfer Pricing Officer (TPO). The TPO's jurisdiction was emphasized to be limited to determining the Arm's Length Price (ALP) without questioning the necessity of the expenditure. The Tribunal rejected the application of the benefit test by the TPO and dismissed other grounds related to penalty proceedings and interest charges. Case-Laws Income Tax Thu, 22 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434388