https://www.taxtmi.com/caselaws?id=247970 Disallowance of cost reimbursements and referral fees under transfer pricing was considered. The TPO must determine the ALP for intra-group cost reimbursements and benchmarking under Rule 10C is required because costs alone do not establish arm's length pricing; matter remitted to the TPO for ALP determination and back to the AO for assessment. Separately, the AO retains jurisdiction to test under the business purpose standard whether referral fees correspond to actual services; the HC set aside the ITAT finding that ousted AO scrutiny, remitted the referralfee issue to the AO for factual verification, and decided in favour of revenue on that point. en-us Fri, 23 May 2014 00:00:00 +0530 Thu, 05 Feb 2026 15:22:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=247970 Disallowance of cost reimbursements and referral fees under transfer pricing was considered. The TPO must determine the ALP for intra-group cost reimbursements and benchmarking under Rule 10C is required because costs alone do not establish arm's length pricing; matter remitted to the TPO for ALP determination and back to the AO for assessment. Separately, the AO retains jurisdiction to test under the business purpose standard whether referral fees correspond to actual services; the HC set aside the ITAT finding that ousted AO scrutiny, remitted the referralfee issue to the AO for factual verification, and decided in favour of revenue on that point. Case-Laws Income Tax Fri, 23 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=247970