https://www.taxtmi.com/caselaws?id=298867 Transfer pricing on intra-group services must be benchmarked under a proper comparability analysis, and a benefit test alone is not sufficient to determine arm's length price. Recurring business accruals created on a consistent, scientific basis and supported by subsequent utilisation or reversal may be allowable. Support service expenditure requires verification of actual services rendered. Annual revenue share licence fees for telecom licences are treated as revenue expenditure when they are recurring payments for use and maintenance. Lease line charges did not attract the withholding obligation invoked. TDS credit is to be granted on verification of the available records. en-us Tue, 22 Oct 2019 00:00:00 +0530 Thu, 25 Nov 2021 07:55:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=298867 Transfer pricing on intra-group services must be benchmarked under a proper comparability analysis, and a benefit test alone is not sufficient to determine arm's length price. Recurring business accruals created on a consistent, scientific basis and supported by subsequent utilisation or reversal may be allowable. Support service expenditure requires verification of actual services rendered. Annual revenue share licence fees for telecom licences are treated as revenue expenditure when they are recurring payments for use and maintenance. Lease line charges did not attract the withholding obligation invoked. TDS credit is to be granted on verification of the available records. Case-Laws Income Tax Tue, 22 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=298867