https://www.taxtmi.com/caselaws?id=214290 Arm's length pricing applies independently even where a payment is structured as reimbursement for alleged intra-group marketing services; the Tribunal found the taxpayer had not shown actual commensurate services, comparable pricing, or compliance with the secondment mechanism, so nil ALP and the transfer pricing adjustment were sustained. A later claim for deduction under Section 10A also failed because the transfer pricing adjustment was not shown to satisfy the statutory requirement of being derived from export profits, and the record did not establish the other conditions for relief. en-us Fri, 30 Mar 2012 00:00:00 +0530 Tue, 23 Jun 2026 11:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214290 Arm's length pricing applies independently even where a payment is structured as reimbursement for alleged intra-group marketing services; the Tribunal found the taxpayer had not shown actual commensurate services, comparable pricing, or compliance with the secondment mechanism, so nil ALP and the transfer pricing adjustment were sustained. A later claim for deduction under Section 10A also failed because the transfer pricing adjustment was not shown to satisfy the statutory requirement of being derived from export profits, and the record did not establish the other conditions for relief. Case-Laws Income Tax Fri, 30 Mar 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214290