https://www.taxtmi.com/caselaws?id=383743 Transfer pricing of closely linked intra-group services may be benchmarked under TNMM at entity level where overall operating margins exceed comparables; a nil arm's-length price cannot rest solely on a benefit test or substituted commercial judgment. Foreign-currency loans to associated enterprises require foreign-currency, LIBOR-based comparables rather than domestic rupee lending rates. Delayed receivables do not automatically constitute unsecured loans, and notional interest requires facts establishing a separate financing arrangement. Software project expenditure may retain revenue character where consistently allowed. Payments to a US group entity do not trigger withholding where services do not make available technical knowledge under the applicable treaty. Goodwill arising from amalgamation is treated as a depreciable intangible asset, and a legal claim may be raised on existing record facts. en-us Fri, 26 Jul 2019 00:00:00 +0530 Mon, 03 Nov 2025 17:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=383743 Transfer pricing of closely linked intra-group services may be benchmarked under TNMM at entity level where overall operating margins exceed comparables; a nil arm's-length price cannot rest solely on a benefit test or substituted commercial judgment. Foreign-currency loans to associated enterprises require foreign-currency, LIBOR-based comparables rather than domestic rupee lending rates. Delayed receivables do not automatically constitute unsecured loans, and notional interest requires facts establishing a separate financing arrangement. Software project expenditure may retain revenue character where consistently allowed. Payments to a US group entity do not trigger withholding where services do not make available technical knowledge under the applicable treaty. Goodwill arising from amalgamation is treated as a depreciable intangible asset, and a legal claim may be raised on existing record facts. Case-Laws Income Tax Fri, 26 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383743