https://www.taxtmi.com/caselaws?id=383743 Transfer pricing analysis notes that closely linked corporate charges and intra-group services may be benchmarked together under TNMM, and a nil ALP adjustment is not justified merely on a benefit test where the assessee's overall margin exceeds comparables. For foreign currency loans to associated enterprises, LIBOR-based benchmarking is the appropriate comparable, not domestic rupee lending rates. The note also treats project expenses as revenue in nature where similar claims were allowed earlier, explains that no TDS obligation arises on payments not chargeable to tax in India under the treaty, recognises goodwill arising on amalgamation as depreciable, and states that delayed receivables cannot be mechanically re-characterised as unsecured loans for notional interest adjustment. 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 analysis notes that closely linked corporate charges and intra-group services may be benchmarked together under TNMM, and a nil ALP adjustment is not justified merely on a benefit test where the assessee's overall margin exceeds comparables. For foreign currency loans to associated enterprises, LIBOR-based benchmarking is the appropriate comparable, not domestic rupee lending rates. The note also treats project expenses as revenue in nature where similar claims were allowed earlier, explains that no TDS obligation arises on payments not chargeable to tax in India under the treaty, recognises goodwill arising on amalgamation as depreciable, and states that delayed receivables cannot be mechanically re-characterised as unsecured loans for notional interest adjustment. Case-Laws Income Tax Fri, 26 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=383743