https://www.taxtmi.com/caselaws?id=275039 In transfer pricing matters involving intra-group management services, the revenue cannot determine arm's length price at nil merely by questioning commercial expediency or perceived benefit, but the assessee must prove actual rendition and receipt of services. On the record, adequate evidence of services received from the associated enterprise was not produced, and the additional material did not conclusively establish rendition. As a result, the nil adjustment to the management service fee was upheld, and the argument that the transaction should be aggregated with other international transactions and benchmarked under TNMM was rejected. en-us Wed, 24 May 2017 00:00:00 +0530 Sun, 16 Sep 2018 18:22:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=275039 In transfer pricing matters involving intra-group management services, the revenue cannot determine arm's length price at nil merely by questioning commercial expediency or perceived benefit, but the assessee must prove actual rendition and receipt of services. On the record, adequate evidence of services received from the associated enterprise was not produced, and the additional material did not conclusively establish rendition. As a result, the nil adjustment to the management service fee was upheld, and the argument that the transaction should be aggregated with other international transactions and benchmarked under TNMM was rejected. Case-Laws Income Tax Wed, 24 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=275039