https://www.taxtmi.com/highlights?id=100611 Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand. en-us Tue, 09 Jun 2026 07:50:17 +0530 Tue, 09 Jun 2026 07:50:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=100611 Royalty-related transfer pricing adjustment was deleted because audited records showed that research and development costs had already been recovered from associated enterprises with a markup of about 10%, making any further adjustment for an alleged unpaid intangible component unwarranted. The adjustment on management support services was also deleted because the assessee had benchmarked interlinked international transactions on an aggregated TNMM basis, and isolating one service for a different method was impermissible. The services, allocation mechanism, and supporting evidence were substantiated, so ALP at nil could not stand. Highlights Income Tax Tue, 09 Jun 2026 07:50:17 +0530 https://www.taxtmi.com/highlights?id=100611