TPO Cannot Question Commercial Expediency of Royalty Transactions; Limited to Arm's Length Price Assessment.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TP Adjustment - royalty paid by the assessee to its AE - the TPO is not vested with any jurisdiction to question the commercial expediency of the transaction carried out by the assessee with its AE, and his jurisdiction is restricted to determining of the arm’s length price of the transaction - AT....