https://www.taxtmi.com/caselaws?id=248536 Profit split method was found unsustainable for the assessee's agency and marketing support services because the record did not show that it performed critical functions, assumed significant risks, or used valuable intangibles. The transfer pricing adjustment was therefore set aside and the arm's length price was directed to be re-determined under a suitable method after fresh factual examination, including proper consideration of TNMM. Club membership expenditure incurred for directors was treated as allowable business expenditure under settled precedent, so the 50% disallowance under section 37(1) was deleted. en-us Tue, 03 Jun 2014 00:00:00 +0530 Sun, 15 Jun 2014 11:20:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=248536 Profit split method was found unsustainable for the assessee's agency and marketing support services because the record did not show that it performed critical functions, assumed significant risks, or used valuable intangibles. The transfer pricing adjustment was therefore set aside and the arm's length price was directed to be re-determined under a suitable method after fresh factual examination, including proper consideration of TNMM. Club membership expenditure incurred for directors was treated as allowable business expenditure under settled precedent, so the 50% disallowance under section 37(1) was deleted. Case-Laws Income Tax Tue, 03 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=248536