Held that accrual of benefit to assessee or commercial expediency of any expenditure incurred by assessee could not be basis for disallowing same. Once margin of profit in distribution segment had been accepted after consideration of management fees, then there was no question of making any separate adjustment insofar as payment of management fees was concerned. Therefore, TPO was not justified in making adjustment in respect of international transaction of Payment of Management Fees. (AY. 2011-12).
Trimble Solutions India (P) Ltd. v. ITO (2022) 217 DTR 257 / 219 TTJ 659 / 141 taxmann.com 331 (Mum)(Trib).
S. 92C : Transfer pricing-Arm’s length-Commercial expediency of expenditure-No separate adjustment is required to be made.