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The ITAT held that the assessee's adoption of the CUP method for benchmarking intra-group royalty payments for central services was appropriate and supported by adequate documentation. The TPO's reliance on an ad-hoc transfer pricing adjustment, without presenting any comparable transactions or applying any prescribed method under section 92C, was found to be contrary to statutory requirements. Consequently, the Tribunal deleted the ad-hoc transfer pricing adjustment made by the AO/TPO. The assessee's appeal was allowed.
The ITAT held that the assessee's adoption of the CUP method for benchmarking intra-group royalty payments for central services was appropriate and supported by adequate documentation. The TPO's reliance on an ad-hoc transfer pricing adjustment, without presenting any comparable transactions or applying any prescribed method under section 92C, was found to be contrary to statutory requirements. Consequently, the Tribunal deleted the ad-hoc transfer pricing adjustment made by the AO/TPO. The assessee's appeal was allowed.
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