The assessee, engaged in the manufacture of two-wheelers, paid export commission to its Japanese Associated Enterprise for export of specified models. The Transfer Pricing Officer determined the arm’s length price of the commission at nil on the ground that no services had been rendered. The Tribunal held that the average export price and profitability from exports were substantially higher than those from domestic sales, demonstrating commercial benefit derived by the assessee. Since the payment was at arm’s length and resulted in higher profitability, the transfer pricing adjustment on export commission was directed to be deleted. The Transfer Pricing Officer determined the arm’s length price of model fees paid by the assessee to its Associated Enterprise for launching new and upgraded models at nil without applying any of the prescribed methods under the Act or the Rules. The Tribunal held that the jurisdiction of the Transfer Pricing Officer is confined to determination of the arm’s length price and he cannot assume the role of a businessman to question the commercial expediency of a transaction or disregard contractual obligations between the parties. As the adjustment was made without following the statutory transfer pricing provisions, the payment was held to be allowable. (AY. 2017-18).