https://www.taxtmi.com/caselaws?id=372942 Distinct contractual management and support services could not be treated as duplicative merely because related group services existed, and the arm's length price could not be fixed at nil where the agreement showed separate functions, separate consideration, and business necessity. The transfer pricing adjustment was therefore deleted. Routine time writing support provided by the overseas group entity did not satisfy the make available test under the India-UK DTAA, so the payment was not fees for technical services and tax deduction at source was not required. The consequential disallowance was also deleted. en-us Mon, 31 Dec 2018 00:00:00 +0530 Thu, 03 Jan 2019 08:12:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=372942 Distinct contractual management and support services could not be treated as duplicative merely because related group services existed, and the arm's length price could not be fixed at nil where the agreement showed separate functions, separate consideration, and business necessity. The transfer pricing adjustment was therefore deleted. Routine time writing support provided by the overseas group entity did not satisfy the make available test under the India-UK DTAA, so the payment was not fees for technical services and tax deduction at source was not required. The consequential disallowance was also deleted. Case-Laws Income Tax Mon, 31 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=372942