https://www.taxtmi.com/highlights?id=99841 The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed. en-us Sat, 16 May 2026 09:09:55 +0530 Sat, 16 May 2026 09:09:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99841 The High Court held that the Bright Line Test could not be adopted for transfer pricing because it is not provided under the Income-tax Act, 1961 or the Rules and is alien to the statutory scheme; the proposed question was rejected. It also declined to entertain the royalty adjustment questions, noting that the need for any transfer pricing adjustment, the computation method, and the arm's length price had already been decided in the assessee's own cases, with no contrary Supreme Court ruling shown. The exclusion of Febulka Advertising Pvt. Ltd. as a comparable was treated as a factual finding based on its different business and incomplete public data, beyond interference under section 260A. The appeal was dismissed. Highlights Income Tax Sat, 16 May 2026 09:09:55 +0530 https://www.taxtmi.com/highlights?id=99841