https://www.taxtmi.com/caselaws?id=393068 Intra-group service payments cannot be benchmarked at nil without applying a prescribed transfer pricing method under section 92C and Rule 10B; where the assessee's benchmarking is rejected, the arm's length price must still be determined under the statutory framework. The article also notes that disputes on sales scheme expenditure and commission accruals under section 40(a)(ia), as well as short TDS credit, required factual verification and fresh adjudication. Tax withheld on foreign currency interest was treated as allowable on a net-of-tax contractual basis, while depreciation on the purchased brand was disallowed in line with the assessee's earlier years. en-us Tue, 18 Feb 2020 00:00:00 +0530 Thu, 05 Mar 2020 13:05:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=393068 Intra-group service payments cannot be benchmarked at nil without applying a prescribed transfer pricing method under section 92C and Rule 10B; where the assessee's benchmarking is rejected, the arm's length price must still be determined under the statutory framework. The article also notes that disputes on sales scheme expenditure and commission accruals under section 40(a)(ia), as well as short TDS credit, required factual verification and fresh adjudication. Tax withheld on foreign currency interest was treated as allowable on a net-of-tax contractual basis, while depreciation on the purchased brand was disallowed in line with the assessee's earlier years. Case-Laws Income Tax Tue, 18 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393068