https://www.taxtmi.com/caselaws?id=782652 ITAT Delhi (AT) held that once the Transfer Pricing Officer (TPO) accepted the combined benchmarking under TNMM for the manufacturing segment, with the Profit Level Indicator already incorporating payment of royalty, a separate arm's length adjustment for the royalty transaction was impermissible. The TPO had determined the assessee's entry-level operating margin of 4.19% as at arm's length while giving effect to DRP directions. ITAT ruled that, having accepted TNMM as the most appropriate method, the TPO could not isolate and re-benchmark only the royalty/technical fee element under a different method. The assessee's appeal was accordingly allowed. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 02 Dec 2025 08:35:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782652 ITAT Delhi (AT) held that once the Transfer Pricing Officer (TPO) accepted the combined benchmarking under TNMM for the manufacturing segment, with the Profit Level Indicator already incorporating payment of royalty, a separate arm's length adjustment for the royalty transaction was impermissible. The TPO had determined the assessee's entry-level operating margin of 4.19% as at arm's length while giving effect to DRP directions. ITAT ruled that, having accepted TNMM as the most appropriate method, the TPO could not isolate and re-benchmark only the royalty/technical fee element under a different method. The assessee's appeal was accordingly allowed. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782652