TPO has no jurisdiction to question commercial expediency or genuineness of need

PCIT Vs Samsung India Electronics Pvt Ltd (Delhi High Court)

Conclusion: In the absence of specific data pertaining to the transactions or of any evidence suggesting that Samsung Korea was in control of the overseas sales by STI to AE’s or unrelated parties, it could not be concluded that the AE’s of STI had not been charged for the cost of technological know-how obtained or that STI had not been renumerated as an independent manufacturer by its AE’s. Sales made by STI to its group companies was driven by open market conditions and was at par with

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