https://www.taxtmi.com/caselaws?id=402233 Arm's length price of intra-group management services cannot be fixed at nil merely because the revenue questions business necessity or perceived benefit. The transaction must be treated as an independent international transaction, with evidence of receipt of services examined and transfer pricing determined through the correct benchmarking method and comparability analysis. On the facts noted, the matter was remitted for fresh consideration on the basis of the documents produced, and the related corporate tax disallowance issue was treated as academic pending that determination. en-us Wed, 25 Nov 2020 00:00:00 +0530 Sat, 26 Dec 2020 11:39:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402233 Arm's length price of intra-group management services cannot be fixed at nil merely because the revenue questions business necessity or perceived benefit. The transaction must be treated as an independent international transaction, with evidence of receipt of services examined and transfer pricing determined through the correct benchmarking method and comparability analysis. On the facts noted, the matter was remitted for fresh consideration on the basis of the documents produced, and the related corporate tax disallowance issue was treated as academic pending that determination. Case-Laws Income Tax Wed, 25 Nov 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402233