https://www.taxtmi.com/caselaws?id=783680 The dominant issue was whether an arm's length price (ALP) adjustment for purchases from an associated enterprise could be sustained when the assessee benchmarked specified domestic transactions under the CUP method. Applying the ratio of HC precedent and consistent ITAT reasoning, the Tribunal held that once CUP was accepted as the most appropriate method and the assessee's documentation supported comparability, the TPO/AO could not substitute an adjustment without first determining ALP under CUP; the ±5% range operates only after ALP determination and, if satisfied, bars adjustment. Consequently, the impugned transfer pricing adjustment on purchases from the AE was deleted and the appeal was allowed. en-us Mon, 15 Dec 2025 00:00:00 +0530 Sat, 20 Dec 2025 07:45:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783680 The dominant issue was whether an arm's length price (ALP) adjustment for purchases from an associated enterprise could be sustained when the assessee benchmarked specified domestic transactions under the CUP method. Applying the ratio of HC precedent and consistent ITAT reasoning, the Tribunal held that once CUP was accepted as the most appropriate method and the assessee's documentation supported comparability, the TPO/AO could not substitute an adjustment without first determining ALP under CUP; the ±5% range operates only after ALP determination and, if satisfied, bars adjustment. Consequently, the impugned transfer pricing adjustment on purchases from the AE was deleted and the appeal was allowed. Case-Laws Income Tax Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783680