https://www.taxtmi.com/highlights?id=98774 Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge. en-us Tue, 14 Apr 2026 08:03:25 +0530 Tue, 14 Apr 2026 08:03:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98774 Transfer pricing on back-to-back project execution was held to be benchmarked under the CUP method rather than TNMM because the assessee acted as a project office for the foreign principal and the relevant transactions were direct services to the associated enterprise. The Tribunal treated the joint venture structure as an administrative vehicle, noted that the project results and related financials were already recorded and taxed in India, and found no realistic profit-shifting concern where the operations and reimbursements were domestic in nature. On that basis, it affirmed deletion of the transfer pricing adjustment and rejected the Revenue's challenge. Highlights Income Tax Tue, 14 Apr 2026 08:03:25 +0530 https://www.taxtmi.com/highlights?id=98774