https://www.taxtmi.com/caselaws?id=768138 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. en-us Mon, 24 Mar 2025 00:00:00 +0530 Mon, 04 Aug 2025 15:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768138 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. Case-Laws Income Tax Mon, 24 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768138