https://www.taxtmi.com/caselaws?id=776557 The ITAT Mumbai held that the assessee correctly applied the CUP method for benchmarking intra-group royalty payments for central services, supported by adequate documentation. The TPO's ad-hoc adjustment, based on the "Other Method" without comparable transactions, was found to be contrary to section 92C of the Act and inconsistent with HC precedents. Consequently, the ad-hoc transfer pricing adjustment was deleted, and the assessee's appeal was allowed. en-us Thu, 22 May 2025 00:00:00 +0530 Wed, 13 Aug 2025 07:27:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776557 The ITAT Mumbai held that the assessee correctly applied the CUP method for benchmarking intra-group royalty payments for central services, supported by adequate documentation. The TPO's ad-hoc adjustment, based on the "Other Method" without comparable transactions, was found to be contrary to section 92C of the Act and inconsistent with HC precedents. Consequently, the ad-hoc transfer pricing adjustment was deleted, and the assessee's appeal was allowed. Case-Laws Income Tax Thu, 22 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776557