https://www.taxtmi.com/caselaws?id=377516 Transfer pricing analysis must determine arm's length price under the prescribed methods; a nil adjustment cannot be sustained merely because the evidence does not fit a rigid Rule 10D checklist, since relevant material bearing on arm's length price remains admissible. The transfer pricing officer's task is limited to benchmarking the international transaction and does not extend to judging commercial necessity. The note also states that capitalised services may still require benchmarking because their value affects future depreciation. A mismatch in the amount adopted for project management fees should be examined and corrected if it is a mistake apparent from the record. 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 analysis must determine arm's length price under the prescribed methods; a nil adjustment cannot be sustained merely because the evidence does not fit a rigid Rule 10D checklist, since relevant material bearing on arm's length price remains admissible. The transfer pricing officer's task is limited to benchmarking the international transaction and does not extend to judging commercial necessity. The note also states that capitalised services may still require benchmarking because their value affects future depreciation. A mismatch in the amount adopted for project management fees should be examined and corrected if it is a mistake apparent from the record. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=377516