https://www.taxtmi.com/caselaws?id=790224 Integrated management services and testing and validation services forming part of a single value chain could not be selectively segregated for transfer pricing purposes where the assessee applied aggregated TNMM, showed a margin above comparables, and supported receipt of services with reports, emails and cost-benefit material. Nil ALP determination was impermissible without a recognised method and cogent evidence, so the TP adjustment was deleted. Outstanding receivables closely linked to sales transactions and already reflected in working capital adjustment did not warrant separate benchmarking, and no notional interest could be imputed in the absence of borrowing cost basis. The adjustment on receivables was also deleted. en-us Tue, 23 Dec 2025 00:00:00 +0530 Wed, 22 Apr 2026 08:47:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790224 Integrated management services and testing and validation services forming part of a single value chain could not be selectively segregated for transfer pricing purposes where the assessee applied aggregated TNMM, showed a margin above comparables, and supported receipt of services with reports, emails and cost-benefit material. Nil ALP determination was impermissible without a recognised method and cogent evidence, so the TP adjustment was deleted. Outstanding receivables closely linked to sales transactions and already reflected in working capital adjustment did not warrant separate benchmarking, and no notional interest could be imputed in the absence of borrowing cost basis. The adjustment on receivables was also deleted. Case-Laws Income Tax Tue, 23 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790224