https://www.taxtmi.com/caselaws?id=762615 In transfer pricing, the arm's length price of management fee for bona fide intra-group services cannot be fixed at nil merely because the revenue questions the need for, or benefit from, the services. The Tribunal held that commercial expediency is for the assessee to determine, and the TPO cannot substitute his own view where the assessee has produced material showing actual services, cost allocation and benchmarking support. As the transaction was not shown to be sham or non-genuine, the nil valuation of the fee was unsustainable and the transfer pricing adjustment had to be deleted in favour of the assessee. en-us Fri, 29 Nov 2024 00:00:00 +0530 Mon, 02 Mar 2026 13:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762615 In transfer pricing, the arm's length price of management fee for bona fide intra-group services cannot be fixed at nil merely because the revenue questions the need for, or benefit from, the services. The Tribunal held that commercial expediency is for the assessee to determine, and the TPO cannot substitute his own view where the assessee has produced material showing actual services, cost allocation and benchmarking support. As the transaction was not shown to be sham or non-genuine, the nil valuation of the fee was unsustainable and the transfer pricing adjustment had to be deleted in favour of the assessee. Case-Laws Income Tax Fri, 29 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762615