https://www.taxtmi.com/caselaws?id=393068 Intra-group service payments cannot be assigned a nil arm's length price merely because the services are considered insufficiently beneficial; where taxpayer benchmarking is rejected, the price must still be determined using a prescribed transfer pricing method under the statutory framework. Sales-scheme expenditure and commission accrual disallowances require factual verification of the payment character, supporting documents, and timing of tax deduction. TDS credit requires reconciliation with Form 26AS. Tax withheld under a net-of-tax foreign-currency borrowing arrangement may form part of allowable interest expenditure where the borrower contractually bears that tax. Depreciation on a purchased brand remained disallowed on identical facts, consistent with the earlier-year position. 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 assigned a nil arm's length price merely because the services are considered insufficiently beneficial; where taxpayer benchmarking is rejected, the price must still be determined using a prescribed transfer pricing method under the statutory framework. Sales-scheme expenditure and commission accrual disallowances require factual verification of the payment character, supporting documents, and timing of tax deduction. TDS credit requires reconciliation with Form 26AS. Tax withheld under a net-of-tax foreign-currency borrowing arrangement may form part of allowable interest expenditure where the borrower contractually bears that tax. Depreciation on a purchased brand remained disallowed on identical facts, consistent with the earlier-year position. Case-Laws Income Tax Tue, 18 Feb 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=393068