https://www.taxtmi.com/caselaws?id=786535 Where payments cover a bundle of proprietary marks, know how and business services charged at a consolidated rate, direct transactional methods (CUP) are preferred if truly comparable transactions exist with equivalent scope of rights/services; if such reliable comparables cannot be identified, applying TNMM on an aggregated basis is a permissible alternative. The CUP comparables used by the TPO were found deficient for lack of comparability; matter is remitted to AO/TPO for de novo benchmarking, permitting selection of proper comparables or application of TNMM and giving the taxpayer a proper opportunity to be heard. en-us Mon, 05 Jan 2026 00:00:00 +0530 Sat, 14 Feb 2026 08:29:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786535 Where payments cover a bundle of proprietary marks, know how and business services charged at a consolidated rate, direct transactional methods (CUP) are preferred if truly comparable transactions exist with equivalent scope of rights/services; if such reliable comparables cannot be identified, applying TNMM on an aggregated basis is a permissible alternative. The CUP comparables used by the TPO were found deficient for lack of comparability; matter is remitted to AO/TPO for de novo benchmarking, permitting selection of proper comparables or application of TNMM and giving the taxpayer a proper opportunity to be heard. Case-Laws Income Tax Mon, 05 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786535