https://www.taxtmi.com/highlights?id=93989 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. en-us Sat, 08 Nov 2025 08:30:03 +0530 Sat, 08 Nov 2025 08:30:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93989 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. Highlights Income Tax Sat, 08 Nov 2025 08:30:03 +0530 https://www.taxtmi.com/highlights?id=93989