TPO Cannot Reject Corporate Fees Based on Benefit; Must Focus on Arm's Length Price Assessment for Transactions.

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Full Text of the Document

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....TP adjustment - Corporate/Management services fee - TPO cannot reject the allowability of expenses simply on the ground that no benefit was derived - It is for the assessee to decide the way in which it has to carry on its business - Once it is proved that the services were availed, then TPO jurisdiction gets restricted to determining the ALP of the transaction.....