https://www.taxtmi.com/caselaws?id=798204 Arm's length price adjustments must use a prescribed method and be supported by comparable, valuation or economic analysis; an ad hoc reallocation of consideration cannot rewrite independently negotiated agreements absent sham, collusion or non-arm's-length dealings. The transfer-pricing adjustment was therefore deleted. Treaty-rate relief for dividend distribution tax under the India-Belgium treaty requires determination in line with the pending Supreme Court resolution, and the refund claim was remitted accordingly. Interest for delayed return filing was deleted because an e-filing portal malfunction beyond the taxpayer's control caused the delay. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798204 Arm's length price adjustments must use a prescribed method and be supported by comparable, valuation or economic analysis; an ad hoc reallocation of consideration cannot rewrite independently negotiated agreements absent sham, collusion or non-arm's-length dealings. The transfer-pricing adjustment was therefore deleted. Treaty-rate relief for dividend distribution tax under the India-Belgium treaty requires determination in line with the pending Supreme Court resolution, and the refund claim was remitted accordingly. Interest for delayed return filing was deleted because an e-filing portal malfunction beyond the taxpayer's control caused the delay. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798204