https://www.taxtmi.com/caselaws?id=192628 Management support service fees paid to an associated enterprise may not be assigned a nil arm's length price merely by questioning business expediency; however, the taxpayer must substantiate that services were actually rendered. Failure to provide convincing evidence of service rendition supports a nil ALP determination and sustains the related transfer pricing adjustment. Aggregation with other international transactions under the Transactional Net Margin Method is available only where transactions are closely linked and form a composite arrangement. Without proof of that linkage, management support fees must not be bundled for benchmarking under TNMM. en-us Fri, 16 Dec 2016 00:00:00 +0530 Thu, 08 Jun 2017 05:56:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=192628 Management support service fees paid to an associated enterprise may not be assigned a nil arm's length price merely by questioning business expediency; however, the taxpayer must substantiate that services were actually rendered. Failure to provide convincing evidence of service rendition supports a nil ALP determination and sustains the related transfer pricing adjustment. Aggregation with other international transactions under the Transactional Net Margin Method is available only where transactions are closely linked and form a composite arrangement. Without proof of that linkage, management support fees must not be bundled for benchmarking under TNMM. Case-Laws Income Tax Fri, 16 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192628