Dismissing the appeal of the revenue , the Tribunal held that , only role assigned to TPO is to find out as to whether international transaction is at arm’s length or not and he is not supposed to take decision about accounting policy to be followed by assessee, nor he should comment upon as to how to compute income if an assessee follows a particular method of accounting . ( AY. 2002 -03
DCIT v. Hazaria Cryogenic Engineering & Construction Management (P.) Ltd. (2018) 168 ITD 344 (Mum) (Trib.)
S.92C:Transfer pricing – Arm’s length price –Method of accounting – TPO has no jurisdiction to comment on the method of accounting followed by an assessee. [ S.145 ]