https://www.taxtmi.com/caselaws?id=784595 The dominant issue was whether intra-group services from an AE were actually rendered so as to justify deduction of the service charges. On review of the audited accounts and nature of functions, the Tribunal held the services were business-oriented, non-duplicative, not shareholder/stewardship or incidental, and not otherwise claimed under different heads; hence the finding that no services were received was untenable, and the expenditure was accepted as incurred, with the ALP determination remitted to the TPO for fresh examination under the prescribed method (appeal grounds on this aspect allowed for statistical purposes). A further issue was the challenge to the TPO/DRP's method; the Tribunal held one of the s.92C(1) methods must apply and, since ALP was already remanded for TNMM verification, the ground alleging improper "other method" application was dismissed. en-us Fri, 14 Nov 2025 00:00:00 +0530 Wed, 07 Jan 2026 16:53:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784595 The dominant issue was whether intra-group services from an AE were actually rendered so as to justify deduction of the service charges. On review of the audited accounts and nature of functions, the Tribunal held the services were business-oriented, non-duplicative, not shareholder/stewardship or incidental, and not otherwise claimed under different heads; hence the finding that no services were received was untenable, and the expenditure was accepted as incurred, with the ALP determination remitted to the TPO for fresh examination under the prescribed method (appeal grounds on this aspect allowed for statistical purposes). A further issue was the challenge to the TPO/DRP's method; the Tribunal held one of the s.92C(1) methods must apply and, since ALP was already remanded for TNMM verification, the ground alleging improper "other method" application was dismissed. Case-Laws Income Tax Fri, 14 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784595