https://www.taxtmi.com/caselaws?id=798014 Final assessment orders under section 144C must conform to Dispute Resolution Panel directions; a consciously adopted adjustment exceeding those directions is invalid and cannot be cured by rectification. For intra-group technical and shared services, transfer-pricing analysis must determine the arm's length price using a prescribed method, not assess commercial expediency or expenditure allowability. Rule 10AB requires the Other Method to consider prices in same or similar uncontrolled transactions between non-associated enterprises. Where no comparable uncontrolled transaction or methodology supports a nil price, the nil valuation and resulting transfer-pricing addition lack a lawful benchmarking basis and require deletion. en-us Wed, 19 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798014 Final assessment orders under section 144C must conform to Dispute Resolution Panel directions; a consciously adopted adjustment exceeding those directions is invalid and cannot be cured by rectification. For intra-group technical and shared services, transfer-pricing analysis must determine the arm's length price using a prescribed method, not assess commercial expediency or expenditure allowability. Rule 10AB requires the Other Method to consider prices in same or similar uncontrolled transactions between non-associated enterprises. Where no comparable uncontrolled transaction or methodology supports a nil price, the nil valuation and resulting transfer-pricing addition lack a lawful benchmarking basis and require deletion. Case-Laws Income Tax Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798014