https://www.taxtmi.com/caselaws?id=790410 Intra-group management fee, technology licence/trademark licence fee, and SAP implementation cost could not be valued at nil where agreements, evidence of rendition, business need, benefit, and scientific cost allocation supported the payments. The Tribunal treated the transactions as linked to the assessee's manufacturing operations and held that benchmarking had to follow the method suited to the integrated business facts; Transactional Net Margin Method was accepted and the transfer pricing adjustments were deleted. Employees' contribution to provident fund/ESIC was not pressed and remained adverse, the penalty challenge was premature, and interest was consequential, so those grounds failed. en-us Wed, 22 Apr 2026 00:00:00 +0530 Fri, 24 Apr 2026 08:52:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790410 Intra-group management fee, technology licence/trademark licence fee, and SAP implementation cost could not be valued at nil where agreements, evidence of rendition, business need, benefit, and scientific cost allocation supported the payments. The Tribunal treated the transactions as linked to the assessee's manufacturing operations and held that benchmarking had to follow the method suited to the integrated business facts; Transactional Net Margin Method was accepted and the transfer pricing adjustments were deleted. Employees' contribution to provident fund/ESIC was not pressed and remained adverse, the penalty challenge was premature, and interest was consequential, so those grounds failed. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790410