ITAT Directs TPO/AO to Delete Adjustment on Export Commission Payment ALP

Honda Motorcycle & Scooter India Pvt Ltd Vs ACIT (ITAT Delhi) In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to delete the adjustment made on account of the arm’s length price (ALP) of export commission payment. The assessee, a subsidiary of Honda Motor Co. Ltd., Japan, had entered into an export agreement with its parent company, whereby it paid export commission at 5% of the freight on board (FOB) value of exports. The TPO rejected the assessee’s transfer pricing methodology a...