https://www.taxtmi.com/caselaws?id=442126 Transfer pricing adjustment on sales to associated enterprises was remanded because the segmental accounts and benchmarking method had been rejected without first examining whether the allocations were prepared on a just and reasonable basis. Intra-group management, SAP, Opti-mill and business area service es were held allowable under section 37(1) once the transactions had been accepted at arm's length; the assessing authority could not apply a separate benefit test contrary to commercial expediency. Reimbursement of bank guarantee commission was not a prior period expense because the invoices were raised in the relevant year, while the tax deduction at source objection was sent back for fresh consideration under the applicable treaty arguments. en-us Thu, 03 Aug 2023 00:00:00 +0530 Fri, 25 Aug 2023 08:32:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442126 Transfer pricing adjustment on sales to associated enterprises was remanded because the segmental accounts and benchmarking method had been rejected without first examining whether the allocations were prepared on a just and reasonable basis. Intra-group management, SAP, Opti-mill and business area service es were held allowable under section 37(1) once the transactions had been accepted at arm's length; the assessing authority could not apply a separate benefit test contrary to commercial expediency. Reimbursement of bank guarantee commission was not a prior period expense because the invoices were raised in the relevant year, while the tax deduction at source objection was sent back for fresh consideration under the applicable treaty arguments. Case-Laws Income Tax Thu, 03 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442126