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    <title>Intra-group service fees to associated enterprise: were services real or duplicative? ALP determination remanded to TPO</title>
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    <description>Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee&#039;s ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO&#039;s use of &quot;other method&quot; without comparables was rejected as meritless and dismissed. - ITAT</description>
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    <pubDate>Thu, 08 Jan 2026 08:28:28 +0530</pubDate>
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      <title>Intra-group service fees to associated enterprise: were services real or duplicative? ALP determination remanded to TPO</title>
      <link>https://www.taxtmi.com/highlights?id=95843</link>
      <description>Disallowance of payments for intra-group services to an associated enterprise was examined on whether services were actually rendered and whether they were duplicative, stewardship, incidental, or on-call. Based on the nature and scale of operations, centralized group support, and audited accounts showing no double-claim of expenses, the tribunal held that the services were received and the expenditure was incurred; however, since the TPO had not examined the assessee&#039;s ALP under the prescribed approach despite TNMM being adopted, ALP determination was remanded to the TPO and the related grounds were allowed for statistical purposes. The challenge to the DRP/TPO&#039;s use of &quot;other method&quot; without comparables was rejected as meritless and dismissed. - ITAT</description>
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