https://www.taxtmi.com/caselaws?id=794302 Transfer pricing adjustment for business-related support services was deleted because the assessee had benchmarked the international transaction under TNMM with comparables and agreement terms, while the adjustment substituted that method without comparable uncontrolled transactions and on an ad hoc basis. The record also showed no adjustment in earlier years for similar transactions, which underscored the inconsistency in the approach. The adjustment was therefore found contrary to the requirement that arm's length price be determined under a prescribed method on a reasoned basis, and the assessee's challenge was allowed. en-us Tue, 23 Jun 2026 00:00:00 +0530 Fri, 03 Jul 2026 08:49:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794302 Transfer pricing adjustment for business-related support services was deleted because the assessee had benchmarked the international transaction under TNMM with comparables and agreement terms, while the adjustment substituted that method without comparable uncontrolled transactions and on an ad hoc basis. The record also showed no adjustment in earlier years for similar transactions, which underscored the inconsistency in the approach. The adjustment was therefore found contrary to the requirement that arm's length price be determined under a prescribed method on a reasoned basis, and the assessee's challenge was allowed. Case-Laws Income Tax Tue, 23 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794302