https://www.taxtmi.com/caselaws?id=786660 Dispute concerned whether TNMM or CUP is the most appropriate method for benchmarking royalty payments and whether royalty receipts must be benchmarked separately. The ITAT accepted remand findings and prior tribunal precedents that TNMM yields arm's length results for the royalty transactions and that aggregating those transactions under TNMM is permissible; the departmental representative failed to show any higher forum reversal. Outcome: TNMM-based benchmarking and deletion of CUP-based transfer pricing adjustments upheld in favour of the assessee. en-us Fri, 13 Feb 2026 00:00:00 +0530 Tue, 17 Feb 2026 07:29:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786660 Dispute concerned whether TNMM or CUP is the most appropriate method for benchmarking royalty payments and whether royalty receipts must be benchmarked separately. The ITAT accepted remand findings and prior tribunal precedents that TNMM yields arm's length results for the royalty transactions and that aggregating those transactions under TNMM is permissible; the departmental representative failed to show any higher forum reversal. Outcome: TNMM-based benchmarking and deletion of CUP-based transfer pricing adjustments upheld in favour of the assessee. Case-Laws Income Tax Fri, 13 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786660