Not Permissible for TPO to Engage in Restructuring of Transaction: Delhi HC dismisses Appeal

In a recent ruling, the Delhi High Court dismissed an appeal challenging the authority of a Transfer Pricing Officer (TPO) to restructure transactions. The case involved the TPO's attempt to alter the terms of inter-company transactions to better reflect market conditions. The court held that the TPO's role is limited to examining and adjusting the pricing of transactions but does not extend to restructuring them. The ruling reinforces the principle that the TPO must adhere strictly to their designated function without overstepping into transaction restructuring, thus maintaining the integrity of the transfer pricing framework.