TPO’s role limited to determining Arm’s Length Price; Not required to comment on commercial wisdom of transaction

ITAT Pune in the case of Eaton Fluid Power Ltd. v ACIT has held that the TPO cannot sit in judgment of the business model of the assessee and its intention to avail or not to avail any services from its AEs. It further held that role of TPO is to determine the Arm’s Length Price of international transactions undertaken by the assessee.

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