Special Leave Petition Dismissed for 476-Day Delay; TNMM Method Upheld for Transfer Pricing Benchmarking Under Section 92C

The SC dismissed the special leave petition due to a 476-day delay in filing, finding no sufficient cause to condone it. The Court concurred with the HC that once the TNMM method was accepted as appropriate for benchmarking the international transactions, the TPO could not apply a different CUP method solely for the royalty payment. However, the dismissal was on procedural grounds related to delay, not on the substantive transfer pricing issue.

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Citation: 2025 (4) TMI 52 - SC - Supreme Court (Order) Summary: The Court noted a delay of "476 days" in filing the special leave petition. It held that "sufficient cause and grounds have not been made out to condone the delay; hence, the application for condonation of delay is dismissed." On that basis, the Court concluded that the "special leave petition is also dismissed." The order disposes of any pending applications. Essential legal reasoning is limited to the procedural ground of inordinate delay and the absence of adequate justification for condonation; no merits determination was reached on the underlying dispute. The decision underscores the strict application of delay-condonation principles in special leave petitions and affirms dismissal where proffered grounds for delay are found insufficient.

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