https://www.taxtmi.com/caselaws?id=780933 ITAT PUNE - AT allowed the assessee's appeal and directed deletion of the transfer pricing adjustment relating to allocation of RHQ charges. The Tribunal held the TPO's adoption of the "Other Method" was unsustainable because no suitable comparable uncontrolled transaction or pricing was brought on record and an arbitrary 50% ad-hoc adjustment to RHQ charges paid to the AE was made. The Tribunal accepted the assessee's aggregation approach applying TNMM as the MAM, finding the TPO/AO failed to follow section 92C and Rule 10AB and therefore the TP adjustment must be deleted. en-us Fri, 10 Oct 2025 00:00:00 +0530 Thu, 06 Nov 2025 16:45:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780933 ITAT PUNE - AT allowed the assessee's appeal and directed deletion of the transfer pricing adjustment relating to allocation of RHQ charges. The Tribunal held the TPO's adoption of the "Other Method" was unsustainable because no suitable comparable uncontrolled transaction or pricing was brought on record and an arbitrary 50% ad-hoc adjustment to RHQ charges paid to the AE was made. The Tribunal accepted the assessee's aggregation approach applying TNMM as the MAM, finding the TPO/AO failed to follow section 92C and Rule 10AB and therefore the TP adjustment must be deleted. Case-Laws Income Tax Fri, 10 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780933