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    <title>2026 (5) TMI 307 - ITAT DELHI</title>
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    <description>An assessment framed without giving effect to binding Dispute Resolution Panel directions was treated as unsustainable where the statutory time for conformity had expired, and the final order was quashed as void. On transfer pricing, the nil valuation of management support services under the &#039;other method&#039; failed because no comparable uncontrolled transaction was brought on record; Rule 10AB required such comparables before rejecting the assessee&#039;s TNMM benchmarking. The adjustment was therefore deleted and the dispute was decided in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791105</link>
      <description>An assessment framed without giving effect to binding Dispute Resolution Panel directions was treated as unsustainable where the statutory time for conformity had expired, and the final order was quashed as void. On transfer pricing, the nil valuation of management support services under the &#039;other method&#039; failed because no comparable uncontrolled transaction was brought on record; Rule 10AB required such comparables before rejecting the assessee&#039;s TNMM benchmarking. The adjustment was therefore deleted and the dispute was decided in favour of the assessee.</description>
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