TPO cannot question need or prudence for making payment of the expenditure

Royal Canin India Private Limited Vs Additional/Joint/Deputy/ Assistant Commissioner of Income Tax (ITAT Mumbai)

ITAT Mumbai held that TPO has jurisdiction to examine the quantum of expenditure, however, TPO has no jurisdiction question the assessee’s need or prudence for making payment for the expenditure.

Facts-

The assessee entered into Franchise Agreement with Royal Canin SAS, France (subsidiary). During the period relevant to AY u

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