https://www.taxtmi.com/caselaws?id=423078 Transfer pricing analysis for intra-group technology licence renewal and management fees indicates that, where the services, know-how and support are integral to the manufacturing business and reliable CUP comparables are unavailable, TNMM is the more appropriate benchmarking method and a nil CUP cannot be constructed merely on perceived lack of direct benefit evidence. For commercial IT support services, the documented invoices, cost allocation on a headcount basis, and consistency with later-year treatment support verification of the charge and corresponding relief if the facts match subsequent years. The document emphasises that business expediency must be assessed from the assessee's perspective and benchmark selection must rest on workable comparables. en-us Tue, 10 May 2022 00:00:00 +0530 Fri, 27 May 2022 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=423078 Transfer pricing analysis for intra-group technology licence renewal and management fees indicates that, where the services, know-how and support are integral to the manufacturing business and reliable CUP comparables are unavailable, TNMM is the more appropriate benchmarking method and a nil CUP cannot be constructed merely on perceived lack of direct benefit evidence. For commercial IT support services, the documented invoices, cost allocation on a headcount basis, and consistency with later-year treatment support verification of the charge and corresponding relief if the facts match subsequent years. The document emphasises that business expediency must be assessed from the assessee's perspective and benchmark selection must rest on workable comparables. Case-Laws Income Tax Tue, 10 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423078