Transfer pricing benchmarking of intra-group services remains pending as the report must be placed on record for further hearing.

Transfer pricing review for intra-group services remained open, as the Delhi HC required the respondent to place the transfer pricing report on record within three weeks for further consideration. The court did not adjudicate the merits of the benchmarking issue and listed the appeals for further hearing, leaving the substantive transfer pricing dispute unresolved at this stage.

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Issues: Whether benchmarking of intra-group services under the transfer pricing regime was undertaken and whether the transfer pricing report should be placed on record for further consideration.

Outcome: The respondent was directed to place the transfer pricing report on record within three weeks and the appeals were listed for further hearing; no final adjudication on the merits took place.

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