https://www.taxtmi.com/caselaws?id=793106 Transfer pricing adjustments on sales to a USA LLC were deleted because the entity operated as the assessee's pass-through arrangement and its income had already been included in Indian taxable income; self-dealing could not generate a separate taxable profit. The related imputed interest adjustment on overdue receivables was also deleted because it was inseparable from the underlying sales adjustment. For specified domestic transactions, the shift from the other method to TNMM and revised comparability filters lacked justification, making the revised eligible-unit profit and consequential reduction of deduction under section 80-IC unsustainable. The challenge to penalty initiation was premature because no final penalty order existed. en-us Wed, 20 May 2026 00:00:00 +0530 Tue, 09 Jun 2026 07:50:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793106 Transfer pricing adjustments on sales to a USA LLC were deleted because the entity operated as the assessee's pass-through arrangement and its income had already been included in Indian taxable income; self-dealing could not generate a separate taxable profit. The related imputed interest adjustment on overdue receivables was also deleted because it was inseparable from the underlying sales adjustment. For specified domestic transactions, the shift from the other method to TNMM and revised comparability filters lacked justification, making the revised eligible-unit profit and consequential reduction of deduction under section 80-IC unsustainable. The challenge to penalty initiation was premature because no final penalty order existed. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793106