https://www.taxtmi.com/caselaws?id=783956 The dominant issue was whether the arm's-length price (ALP) for intra-group management service fees could be determined at Nil and what method was appropriate. The ITAT held that the assessee's cost-plus mark-ups (5% for support and 10% for managerial/technical services) were supported by reliable internal cost data, consistent with OECD guidance on low value-adding intra-group services, and corroborated by a TNMM showing the assessee's 9.96% net cost-plus margin within the interquartile range of comparables; accordingly, a Nil ALP could not be sustained. The TPO's Nil determination, made without applying Rule 10B methods, identifying comparables, or rebutting evidence of services, was set aside; the TP adjustment was deleted, with a direction to verify the TPSR benchmarking under the "Other Method." en-us Mon, 24 Nov 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783956 The dominant issue was whether the arm's-length price (ALP) for intra-group management service fees could be determined at Nil and what method was appropriate. The ITAT held that the assessee's cost-plus mark-ups (5% for support and 10% for managerial/technical services) were supported by reliable internal cost data, consistent with OECD guidance on low value-adding intra-group services, and corroborated by a TNMM showing the assessee's 9.96% net cost-plus margin within the interquartile range of comparables; accordingly, a Nil ALP could not be sustained. The TPO's Nil determination, made without applying Rule 10B methods, identifying comparables, or rebutting evidence of services, was set aside; the TP adjustment was deleted, with a direction to verify the TPSR benchmarking under the "Other Method." Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783956