https://www.taxtmi.com/caselaws?id=793106 Transfer pricing on sales to a USA LLC treated as a pass-through was considered unsustainable where the entity's income had already been included in the assessee's Indian taxable income; the related receivables adjustment also fell because it was merely ancillary to the deleted sales adjustment. For specified domestic transactions, the note states that shifting from the assessee's method to TNMM, with altered comparables and filters, was unjustified where the disclosed margin remained consistent with the accepted range, so the corresponding section 80-IC reduction was not sustainable. Initiation of penalty proceedings under section 270A was treated as premature at the initiation stage. 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 on sales to a USA LLC treated as a pass-through was considered unsustainable where the entity's income had already been included in the assessee's Indian taxable income; the related receivables adjustment also fell because it was merely ancillary to the deleted sales adjustment. For specified domestic transactions, the note states that shifting from the assessee's method to TNMM, with altered comparables and filters, was unjustified where the disclosed margin remained consistent with the accepted range, so the corresponding section 80-IC reduction was not sustainable. Initiation of penalty proceedings under section 270A was treated as premature at the initiation stage. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793106