https://www.taxtmi.com/caselaws?id=386259 An arm's length price for intra-group marketing support and global infrastructure support services cannot be fixed at nil merely on a benefit-test or commercial expediency view when the assessee has produced agreements, emails, presentations, cost allocation records and accountant certification showing receipt of services and allocation of costs. A prescribed transfer pricing method and proper consideration of the documentary evidence were required, so the nil adjustment was deleted. Where the assessee had already suo motu disallowed an amount under section 40(a)(i) for non-deduction of tax at source, the same disallowance could not be made again in the assessment year; the duplicate disallowance was held impermissible and consequential relief followed. en-us Tue, 25 Jun 2019 00:00:00 +0530 Wed, 25 Sep 2019 07:49:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386259 An arm's length price for intra-group marketing support and global infrastructure support services cannot be fixed at nil merely on a benefit-test or commercial expediency view when the assessee has produced agreements, emails, presentations, cost allocation records and accountant certification showing receipt of services and allocation of costs. A prescribed transfer pricing method and proper consideration of the documentary evidence were required, so the nil adjustment was deleted. Where the assessee had already suo motu disallowed an amount under section 40(a)(i) for non-deduction of tax at source, the same disallowance could not be made again in the assessment year; the duplicate disallowance was held impermissible and consequential relief followed. Case-Laws Income Tax Tue, 25 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386259