https://www.taxtmi.com/caselaws?id=377516 Transfer pricing authorities must determine the arm's length price of technical assistance and project management fees using prescribed methods and cannot assign a nil value merely by questioning commercial necessity. Relevant evidence of services received, including agreements, correspondence and associated-enterprise certificates, may be considered even if it does not conform to a rigid reading of Rule 10D. Capitalised international transactions also require benchmarking where their valuation affects future depreciation. The fee adjustments require fresh arm's length price determination after allowing supporting evidence. A mismatch between the project management fee recorded and the amount used for adjustment requires verification and rectification if it is an apparent record error. en-us Fri, 15 Feb 2019 00:00:00 +0530 Fri, 29 Mar 2019 16:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=377516 Transfer pricing authorities must determine the arm's length price of technical assistance and project management fees using prescribed methods and cannot assign a nil value merely by questioning commercial necessity. Relevant evidence of services received, including agreements, correspondence and associated-enterprise certificates, may be considered even if it does not conform to a rigid reading of Rule 10D. Capitalised international transactions also require benchmarking where their valuation affects future depreciation. The fee adjustments require fresh arm's length price determination after allowing supporting evidence. A mismatch between the project management fee recorded and the amount used for adjustment requires verification and rectification if it is an apparent record error. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377516