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ITAT held that the TPO's ad-hoc 50% adjustment to RHQ charges lacked a suitable comparable and did not comply with Rule 10AB or section 92C, rendering the benchmarking unsustainable; the TPO failed to apply any prescribed method or to bring a comparable uncontrolled price on record when invoking the "Other Method," and therefore the ALP determination was void. On the facts and law the Tribunal accepted the Taxpayer's aggregation/TNMM as the Most Appropriate Method and directed deletion of the entire transfer-pricing adjustment relating to allocation of RHQ charges, noting the AO/TPO's non-compliance with statutory provisions and absence of rebuttal material from the Revenue.
ITAT held that the TPO's ad-hoc 50% adjustment to RHQ charges lacked a suitable comparable and did not comply with Rule 10AB or section 92C, rendering the benchmarking unsustainable; the TPO failed to apply any prescribed method or to bring a comparable uncontrolled price on record when invoking the "Other Method," and therefore the ALP determination was void. On the facts and law the Tribunal accepted the Taxpayer's aggregation/TNMM as the Most Appropriate Method and directed deletion of the entire transfer-pricing adjustment relating to allocation of RHQ charges, noting the AO/TPO's non-compliance with statutory provisions and absence of rebuttal material from the Revenue.
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