https://www.taxtmi.com/caselaws?id=787360 Transfer pricing adjustment rejecting royalty payments on an ad hoc NIL arm's length price is unsustainable where the TPO/AO fails to apply any statutory method; documented benchmarking using CUP/TNMM and comparability review supports deletion of the adjustment, and the appellate deletions are upheld. Separately, a typographical name discrepancy in a contract does not defeat eligibility for deduction where documentary evidence (agreement, work orders, invoices, payment advices, performance certificates and tax records) establishes that the assessee independently performed and accounted for supply, installation and commissioning obligations; the 80IA(4) deduction is therefore correctly allowed. en-us Tue, 24 Feb 2026 00:00:00 +0530 Mon, 02 Mar 2026 14:33:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787360 Transfer pricing adjustment rejecting royalty payments on an ad hoc NIL arm's length price is unsustainable where the TPO/AO fails to apply any statutory method; documented benchmarking using CUP/TNMM and comparability review supports deletion of the adjustment, and the appellate deletions are upheld. Separately, a typographical name discrepancy in a contract does not defeat eligibility for deduction where documentary evidence (agreement, work orders, invoices, payment advices, performance certificates and tax records) establishes that the assessee independently performed and accounted for supply, installation and commissioning obligations; the 80IA(4) deduction is therefore correctly allowed. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787360