Tribunal held that TPO cannot decide whether expenses were necessary for conducting business or whether any benefit had been derive from expenditure so incurred and thus, DRP was justified in deleting impugned addition. (AY. 2006-07, 2007-08)
DCIT v. Rabo India Finance Ltd. (2021) 189 ITD 420 (Mum.) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-TPO cannot decide as to whether expenses incurred by assessee were necessary for business purpose of assessee or not. [S. 37 (1)]