Not Permissible For TPO To Engage In Restructuring Of Transaction: Delhi High Court

In a recent ruling, the Delhi High Court upheld the decisions of the Income Tax Appellate Tribunal (ITAT) regarding the allocation of marketing expenses and other intra-group costs under the Income Tax Act, 1961. The Tribunal's judgment was confirmed after a thorough examination of the Transfer Pricing Officer's (TPO) actions and the commercial rationale behind the expenses claimed. Case Background: The case involved a detailed scrutiny of marketing and advertising…