https://www.taxtmi.com/caselaws?id=789274 Transfer pricing adjustment on management fees was sent back for fresh adjudication because receipt of services, cost allocation, benefit analysis, and the choice of method required further verification, and a similar issue had already been restored in an earlier year. The claim to restrict dividend distribution tax under the tax treaty was also remanded, as the later Bombay High Court ruling on the treaty treatment of dividend taxation and the rate cap required reconsideration of the factual and treaty conditions. No substantive relief was granted on merits; the assessee received only statistical relief. en-us Thu, 02 Apr 2026 00:00:00 +0530 Mon, 06 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789274 Transfer pricing adjustment on management fees was sent back for fresh adjudication because receipt of services, cost allocation, benefit analysis, and the choice of method required further verification, and a similar issue had already been restored in an earlier year. The claim to restrict dividend distribution tax under the tax treaty was also remanded, as the later Bombay High Court ruling on the treaty treatment of dividend taxation and the rate cap required reconsideration of the factual and treaty conditions. No substantive relief was granted on merits; the assessee received only statistical relief. Case-Laws Income Tax Thu, 02 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789274