https://www.taxtmi.com/caselaws?id=794609 Section 80-IA(10) applies as an anti-abuse provision only where the tax authority establishes, on cogent objective material, a close connection, an arranged course of business, and more than ordinary profits; mere high profitability or the existence of transactions is insufficient. On the facts discussed, no reliable benchmarking or other material showed profit inflation, so the transfer pricing adjustment was deleted. The related challenge to the TPO reference and Chapter X jurisdiction was not finally decided on merits and was dealt with in line with the assessee's earlier year order. en-us Mon, 29 Jun 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794609 Section 80-IA(10) applies as an anti-abuse provision only where the tax authority establishes, on cogent objective material, a close connection, an arranged course of business, and more than ordinary profits; mere high profitability or the existence of transactions is insufficient. On the facts discussed, no reliable benchmarking or other material showed profit inflation, so the transfer pricing adjustment was deleted. The related challenge to the TPO reference and Chapter X jurisdiction was not finally decided on merits and was dealt with in line with the assessee's earlier year order. Case-Laws Income Tax Mon, 29 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794609