ITAT Deletes TP Adjustments on Royalty and Management Support Services

The Pune Bench of the Income Tax Appellate Tribunal, in its order dated 1 June 2026, allowed the appeal filed by L&L Product India Private Limited for AY 2021-22 by deleting transfer pricing adjustments relating to royalty payments and management support services. 

The Tribunal held that the royalty component had already been recovered with an appropriate mark-up and that the Transfer Pricing Officer was not justified in isolating the management support services transaction for benchmarking under a different method after accepting TNMM for the remaining international transactions. 

The ruling reinforces settled principles governing benchmarking consistency and evaluation of intra-group service arrangements.