https://www.taxtmi.com/caselaws?id=793114 Royalty-related transfer pricing adjustment was deleted because the assessee had already recovered research and product development costs from associated enterprises with a 10% markup, and the adjustment ignored that disclosed revenue. Management support services adjustment was also deleted because the assessee had benchmarked the inter-linked transactions under TNMM and supported the services with agreements, role descriptions, e-mails, allocation workings and past acceptance; isolating one element for a different method and treating the services as duplicative was held inconsistent with the grouped benchmarking approach. Both additions were therefore disallowed, giving the assessee full relief on the substantive grounds. en-us Mon, 01 Jun 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793114 Royalty-related transfer pricing adjustment was deleted because the assessee had already recovered research and product development costs from associated enterprises with a 10% markup, and the adjustment ignored that disclosed revenue. Management support services adjustment was also deleted because the assessee had benchmarked the inter-linked transactions under TNMM and supported the services with agreements, role descriptions, e-mails, allocation workings and past acceptance; isolating one element for a different method and treating the services as duplicative was held inconsistent with the grouped benchmarking approach. Both additions were therefore disallowed, giving the assessee full relief on the substantive grounds. Case-Laws Income Tax Mon, 01 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793114