TPO Exceeded Authority by Evaluating Business Justification for Royalty Payments Instead of Using Scientific Methods, Section 92CA(3.

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....TPA - ALP of payment of royalty u/s 92CA(3) - TPO instead of applying of the specified scientific methods went on to the justification of the purchase made in the context of the incremental benefit earned out of such know-how which was clearly not within his purview as he could not replace the assessee and question its business decision - payment within RBI approved limit - ALP accepted....