https://www.taxtmi.com/caselaws?id=408268 Transfer pricing of management services cannot be reduced to nil solely because the taxpayer's business benefit is questioned. Where documentation supports receipt and genuineness of services, arm's length pricing must apply a prescribed benchmarking method rather than a subjective benefit analysis. Interest on outstanding receivables from associated enterprises must likewise be benchmarked under the transfer pricing framework using an appropriate method and comparable conditions. Reliance on an unrelated domestic prime lending rate without selecting and applying the most appropriate method does not support an adjustment. On these principles, the management-services and receivables-interest adjustments were treated as unsustainable. en-us Tue, 04 May 2021 00:00:00 +0530 Sat, 05 Jun 2021 10:40:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=408268 Transfer pricing of management services cannot be reduced to nil solely because the taxpayer's business benefit is questioned. Where documentation supports receipt and genuineness of services, arm's length pricing must apply a prescribed benchmarking method rather than a subjective benefit analysis. Interest on outstanding receivables from associated enterprises must likewise be benchmarked under the transfer pricing framework using an appropriate method and comparable conditions. Reliance on an unrelated domestic prime lending rate without selecting and applying the most appropriate method does not support an adjustment. On these principles, the management-services and receivables-interest adjustments were treated as unsustainable. Case-Laws Income Tax Tue, 04 May 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=408268