https://www.taxtmi.com/caselaws?id=786168 Transfer pricing adjustment challenged the use of commission received as the arm's length benchmark for commission paid on import and export transactions; the benchmarking was held impermissible because the commission received did not reflect uncontrolled transactions or dealings between non-associated parties, so the ad hoc addition based on a thumb rule was deleted. The tribunal observed the TPO/AO applied the adjustment without providing opportunity to the taxpayer and directed deletion of the addition. The AO was directed to revisit interest consequences: verify and compute interest under consequential provisions and confirm return filing due dates before taking action on interest relating to delayed filing. en-us Wed, 04 Feb 2026 00:00:00 +0530 Sat, 07 Feb 2026 07:19:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786168 Transfer pricing adjustment challenged the use of commission received as the arm's length benchmark for commission paid on import and export transactions; the benchmarking was held impermissible because the commission received did not reflect uncontrolled transactions or dealings between non-associated parties, so the ad hoc addition based on a thumb rule was deleted. The tribunal observed the TPO/AO applied the adjustment without providing opportunity to the taxpayer and directed deletion of the addition. The AO was directed to revisit interest consequences: verify and compute interest under consequential provisions and confirm return filing due dates before taking action on interest relating to delayed filing. Case-Laws Income Tax Wed, 04 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786168