TPO Cannot question business purpose of transaction

ITAT Delhi Ericsson India Pvt. Ltd vs. DCIT ITA NO. 5141/Del/2011 Assessment Year 2007-2008 Date of Order Pronouncement – 11/05/2012 There is no force in the Revenue’s claim that the assessee was not required to make any payment to its AE for resolving warranty claims. The assessee has the right to enter into an arrangement according to which its business interests are protected. It is the prerogative of the assessee to decide the business expediency. Rule 10B(1)(a) does not authorize disallowance of any expendtture on the ground that it was not necessary or prudent fo...