TPO’s scope is limited to computing arm’s length price of a transaction

Honda Motorcycle and Scooter India Pvt. Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi deleted TP adjustment on payment of model fee for export to AEs stating that scope of TPO is limited to determination of arm’s length price and TPO cannot adjudge commercial expediency of a transaction. Facts- The assessee is a subsidiary of Honda Motor Co. Ltd. Japan. The assessee had entered into an Export Agreement dated 13.07.2000 under which Honda Motor Co. Ltd. Japan (HMJ) accorded consent to the assessee to export specific models of two wheelers to certain countries on payment of export commission @ 5% of the...