https://www.taxtmi.com/caselaws?id=779129 ITAT held that the transfer-pricing adjustment under section 92CA(3) was arbitrary where the DRP upheld rejection of the assessee's TNMM and invoked the "other method" for pricing "other support services" but the DRP's adhoc 50% ALP disallowance lacked statutory basis. The Tribunal found the TPO could apply the other method but must compute ALP per the Act's procedure, not by ad hoc percentage. Matter remitted to AO for fresh benchmarking and computation after affording the assessee an opportunity to produce evidence; appeal allowed for statistical purposes. en-us Mon, 18 Aug 2025 00:00:00 +0530 Mon, 29 Sep 2025 08:27:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779129 ITAT held that the transfer-pricing adjustment under section 92CA(3) was arbitrary where the DRP upheld rejection of the assessee's TNMM and invoked the "other method" for pricing "other support services" but the DRP's adhoc 50% ALP disallowance lacked statutory basis. The Tribunal found the TPO could apply the other method but must compute ALP per the Act's procedure, not by ad hoc percentage. Matter remitted to AO for fresh benchmarking and computation after affording the assessee an opportunity to produce evidence; appeal allowed for statistical purposes. Case-Laws Income Tax Mon, 18 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779129