https://www.taxtmi.com/caselaws?id=787367 Transfer pricing adjustment challenged: the TPO must examine the assessee's internal comparable uncontrolled price (CUP) method where the DRP directed its consideration, and two opening NCDs excluded by the TPO's own filters cannot sustain adjustment; the disputed NCD at 13.20% is to be re-benchmarked using the internal CUP. A fresh deduction claim for customer incentives, though not in the original return, is admissible for quantification and remitted to the assessing officer for fresh adjudication. Correct statutory interest on any refund under the refund provision is to be calculated and allowed. Challenge to initiation of penalty proceedings is premature and dismissed. en-us Fri, 27 Feb 2026 00:00:00 +0530 Tue, 03 Mar 2026 08:42:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787367 Transfer pricing adjustment challenged: the TPO must examine the assessee's internal comparable uncontrolled price (CUP) method where the DRP directed its consideration, and two opening NCDs excluded by the TPO's own filters cannot sustain adjustment; the disputed NCD at 13.20% is to be re-benchmarked using the internal CUP. A fresh deduction claim for customer incentives, though not in the original return, is admissible for quantification and remitted to the assessing officer for fresh adjudication. Correct statutory interest on any refund under the refund provision is to be calculated and allowed. Challenge to initiation of penalty proceedings is premature and dismissed. Case-Laws Income Tax Fri, 27 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787367