https://www.taxtmi.com/caselaws?id=784164 Transfer pricing adjustment on inter-group services was examined. The ITAT held that the AE's IGS/ITSS services were not stewardship or shareholder activities; on evidence and precedent the payment, including markup on third-party costs, was at arm's length, so the TP addition was deleted. On marketing support services, the ITAT applied the rule of consistency as TNMM had been accepted in earlier years and held CUP was unsuitable due to stringent comparability requirements not being met; the TP addition was directed to be deleted. On employees' PF contribution, a one-day delay due to technical difficulty required rectification; the AO was directed to pass a rectification order after hearing, allowing the ground for statistical purposes. On CSR-linked donation, Section 37 disallowance did not bar Section 80G relief for eligible donations (other than specified funds); deduction under Section 80G was directed to be allowed. en-us Fri, 05 Dec 2025 00:00:00 +0530 Tue, 30 Dec 2025 09:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784164 Transfer pricing adjustment on inter-group services was examined. The ITAT held that the AE's IGS/ITSS services were not stewardship or shareholder activities; on evidence and precedent the payment, including markup on third-party costs, was at arm's length, so the TP addition was deleted. On marketing support services, the ITAT applied the rule of consistency as TNMM had been accepted in earlier years and held CUP was unsuitable due to stringent comparability requirements not being met; the TP addition was directed to be deleted. On employees' PF contribution, a one-day delay due to technical difficulty required rectification; the AO was directed to pass a rectification order after hearing, allowing the ground for statistical purposes. On CSR-linked donation, Section 37 disallowance did not bar Section 80G relief for eligible donations (other than specified funds); deduction under Section 80G was directed to be allowed. Case-Laws Income Tax Fri, 05 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784164