https://www.taxtmi.com/caselaws?id=272741 Controlled international transactions linked to distinct business segments should be benchmarked segment-wise where reliable segmental data exists; an entity-level combined test that mixes international and domestic activity distorts comparability and is inappropriate absent close linkage. Management services supported by documentary evidence and business utility cannot be treated as stewardship services or assigned a nil value without proper transfer pricing analysis. Royalty paid for commercially useful technology and technical assistance must be tested against a valid benchmarking study, and nil ALP requires statutory basis. Depreciation is allowable on acquired intellectual property rights and goodwill. Warranty, MSMED interest and inventory obsolescence provisions may be deductible, though inventory obsolescence can still require MAT add-back. en-us Wed, 13 Sep 2017 00:00:00 +0530 Wed, 16 May 2018 14:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272741 Controlled international transactions linked to distinct business segments should be benchmarked segment-wise where reliable segmental data exists; an entity-level combined test that mixes international and domestic activity distorts comparability and is inappropriate absent close linkage. Management services supported by documentary evidence and business utility cannot be treated as stewardship services or assigned a nil value without proper transfer pricing analysis. Royalty paid for commercially useful technology and technical assistance must be tested against a valid benchmarking study, and nil ALP requires statutory basis. Depreciation is allowable on acquired intellectual property rights and goodwill. Warranty, MSMED interest and inventory obsolescence provisions may be deductible, though inventory obsolescence can still require MAT add-back. Case-Laws Income Tax Wed, 13 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272741