https://www.taxtmi.com/caselaws?id=789750 In a back-to-back construction arrangement where joint ventures functioned only as routing or administrative conduits, the Tribunal held that the comparable uncontrolled price method was the proper benchmark because the controlled transaction mirrored the uncontrolled transaction and receipts passed through without value addition; the transactional net margin method was wrongly applied. It also held that reimbursements on a cost-to-cost basis, capital contributions, mobilisation advances, and interim-payment or variation-adjustment flows were not liable to transfer pricing adjustment, as they were pass-through or capital movements without service markup and the relevant project receipts were already taxed in India. en-us Thu, 12 Feb 2026 00:00:00 +0530 Wed, 15 Apr 2026 10:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789750 In a back-to-back construction arrangement where joint ventures functioned only as routing or administrative conduits, the Tribunal held that the comparable uncontrolled price method was the proper benchmark because the controlled transaction mirrored the uncontrolled transaction and receipts passed through without value addition; the transactional net margin method was wrongly applied. It also held that reimbursements on a cost-to-cost basis, capital contributions, mobilisation advances, and interim-payment or variation-adjustment flows were not liable to transfer pricing adjustment, as they were pass-through or capital movements without service markup and the relevant project receipts were already taxed in India. Case-Laws Income Tax Thu, 12 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789750