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Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowan...
Arm's length pricing for intra-group support services cannot be...
Transfer pricing of intra-group support services requires prescribed benchmarking; unsupported nil valuation and alternate business-expense disallowance fail.
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Arm's length pricing for intra-group support services cannot be fixed at nil merely because adequate benefit from the expenditure is not established. Where existing benchmarking is rejected, the price must be determined through the most appropriate prescribed method and objective comparables; agreements, invoices, allocation workings and personnel material require cumulative assessment. Closely linked transactions benchmarked under TNMM cannot be selectively separated without proper basis. Evidence of actual operational support and business nexus supports deduction where no capital, personal or prohibited purpose is shown. The transfer-pricing adjustment and alternate disallowance were deleted. Interest under section 234C must be computed on tax due on returned income and recomputed accordingly.
Arm's length pricing for intra-group support services cannot be fixed at nil merely because adequate benefit from the expenditure is not established. Where existing benchmarking is rejected, the price must be determined through the most appropriate prescribed method and objective comparables; agreements, invoices, allocation workings and personnel material require cumulative assessment. Closely linked transactions benchmarked under TNMM cannot be selectively separated without proper basis. Evidence of actual operational support and business nexus supports deduction where no capital, personal or prohibited purpose is shown. The transfer-pricing adjustment and alternate disallowance were deleted. Interest under section 234C must be computed on tax due on returned income and recomputed accordingly.
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