https://www.taxtmi.com/caselaws?id=467980 Transfer pricing adjustment for management support services cannot be sustained at nil where the services are supported by the service arrangement, debit notes and correspondence, and are shown to be integral to business operations. The arm's length mark-up of 5% was treated as reasonable, especially since the expenditure was not separately booked in the financials and similar payments had been accepted in earlier years. The Tribunal noted that the Revenue had taken an inconsistent approach without distinguishing earlier assessment years where relief had already been granted. On that basis, the nil valuation was rejected and the upward adjustment was deleted. en-us Wed, 14 May 2025 00:00:00 +0530 Fri, 10 Apr 2026 20:17:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467980 Transfer pricing adjustment for management support services cannot be sustained at nil where the services are supported by the service arrangement, debit notes and correspondence, and are shown to be integral to business operations. The arm's length mark-up of 5% was treated as reasonable, especially since the expenditure was not separately booked in the financials and similar payments had been accepted in earlier years. The Tribunal noted that the Revenue had taken an inconsistent approach without distinguishing earlier assessment years where relief had already been granted. On that basis, the nil valuation was rejected and the upward adjustment was deleted. Case-Laws Income Tax Wed, 14 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467980