https://www.taxtmi.com/caselaws?id=794451 Safe Harbour rules could not be used to rework distribution segment profitability where the assessee had not elected those provisions, and the assessee's segmental allocation based on actuals and reasonable keys was accepted. Transfer pricing adjustments for intra-group services and lump sum licence fee/royalty could not be sustained at nil ALP under the Other Method without comparable uncontrolled transactions, and the related adjustments were deleted. Trademark fee already absorbed in the TNMM cost base could not be separately benchmarked again, as that would create an impermissible double adjustment; the TNMM treatment was therefore respected subject to verification. en-us Mon, 30 Mar 2026 00:00:00 +0530 Mon, 06 Jul 2026 08:26:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794451 Safe Harbour rules could not be used to rework distribution segment profitability where the assessee had not elected those provisions, and the assessee's segmental allocation based on actuals and reasonable keys was accepted. Transfer pricing adjustments for intra-group services and lump sum licence fee/royalty could not be sustained at nil ALP under the Other Method without comparable uncontrolled transactions, and the related adjustments were deleted. Trademark fee already absorbed in the TNMM cost base could not be separately benchmarked again, as that would create an impermissible double adjustment; the TNMM treatment was therefore respected subject to verification. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794451