https://www.taxtmi.com/caselaws?id=192628 Transfer pricing analysis confirms that arm's length price for management support services cannot be set at nil merely by doubting commercial expediency; the taxpayer must still demonstrate that the associated enterprise actually rendered the services. Where the evidence does not substantiate rendition, a nil ALP determination is sustained. The note also states that management support fees may be aggregated with other international transactions only when they are closely linked and part of a composite arrangement. In the absence of such linkage, benchmarking the bundled transaction under TNMM is not accepted, and the transfer pricing adjustment is maintained. 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 Transfer pricing analysis confirms that arm's length price for management support services cannot be set at nil merely by doubting commercial expediency; the taxpayer must still demonstrate that the associated enterprise actually rendered the services. Where the evidence does not substantiate rendition, a nil ALP determination is sustained. The note also states that management support fees may be aggregated with other international transactions only when they are closely linked and part of a composite arrangement. In the absence of such linkage, benchmarking the bundled transaction under TNMM is not accepted, and the transfer pricing adjustment is maintained. Case-Laws Income Tax Fri, 16 Dec 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=192628