2025 (4) TMI 52 - SCH - Income Tax

TP Adjustment - MAM for Royalty payment - TPO has accepted the TNMM method as the most appropriate method to benchmark Assessee s international transactions under the manufacturing activity but decided to separately benchmark the royalty - as decided by HC 2023 (8) TMI 458 - BOMBAY HIGH COURT we would concur with Appellant that having accepted the TNMM method as the most appropriate it was not open to the TPO to subject only one element i.e payment of royalty to an entirely different CUP method HELD THAT - There is a delay of 476 days in the filing of the present special leave petition. In our opinion sufficient cause and grounds have not been made out to condone the delay; hence the application for condonation of delay is dismissed. Consequently the special leave petition is also dismissed.

Summary

**Supreme Court Judgment Summary****Case Citation:** TMI**Judges:** Hon'ble Chief Justice Sanjiv Khanna, Hon'ble Mr. Justice Sanjay Kumar, Hon'ble Mr. Justice K.V. Viswanathan**Parties:**- **For the Petitioner:** Mr. N Venkataraman (A.S.G.), Mr. Raj Bahadur Yadav (AOR), Mr. Karan Lahiri, Mr. Aaditya Shankar Dixit, Mr. Digvijay Dam, Mr. Ram Krishna Rao- **For the Respondent:** Mr. Jehangir Mistri (Sr. Adv.), Mr. Bhargava V. Desai (AOR), Mr. Shivam Sharma, Mrs. Gauri P Desai**Order:**The Supreme Court addressed a "delay of 476 days" in filing the special leave petition. The Court concluded that "sufficient cause and grounds have not been made out to condone the delay," and therefore, the application for condonation of delay was dismissed. As a result, the special leave petition was also dismissed. Any pending applications were ordered to be disposed of.