https://www.taxtmi.com/caselaws?id=754122 ITAT Mumbai held that TPO exceeded jurisdiction by examining management service fee payment to associated enterprises under section 37 instead of determining arm's length price (ALP) under section 92CA. TPO's role is limited to ALP determination for covered transactions, not examining allowability of expenses. The TPO issued questionnaire under section 37 provisions, which falls outside his domain, and determined benchmarking value at nil without proper ALP working. Matter was restored to TPO for proper ALP determination per statutory scheme with reasonable opportunity for assessee to present transfer pricing study and comparables. en-us Wed, 08 May 2024 00:00:00 +0530 Tue, 18 Jun 2024 08:29:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754122 ITAT Mumbai held that TPO exceeded jurisdiction by examining management service fee payment to associated enterprises under section 37 instead of determining arm's length price (ALP) under section 92CA. TPO's role is limited to ALP determination for covered transactions, not examining allowability of expenses. The TPO issued questionnaire under section 37 provisions, which falls outside his domain, and determined benchmarking value at nil without proper ALP working. Matter was restored to TPO for proper ALP determination per statutory scheme with reasonable opportunity for assessee to present transfer pricing study and comparables. Case-Laws Income Tax Wed, 08 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754122