https://www.taxtmi.com/caselaws?id=791350 Transfer pricing on technical and training services was analysed on the basis of the assessee's functional profile and benchmarking. The assessee was found to act only as a coordinating and liaison entity for after-sales support, while the associated enterprise owned the key intangibles, assets, and risk-bearing functions. Because the assessee lacked the proprietary knowledge and resources to independently render the services, and the contractual risks remained with the associated enterprise, it was characterised as a limited-risk service provider. Its consistent TNMM benchmarking, accepted in the preceding year, could not be displaced merely due to non-filing of parent contracts where confidentiality concerns existed and the DRP had already directed reconsideration of the evidence. en-us Wed, 06 May 2026 00:00:00 +0530 Thu, 07 May 2026 17:40:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791350 Transfer pricing on technical and training services was analysed on the basis of the assessee's functional profile and benchmarking. The assessee was found to act only as a coordinating and liaison entity for after-sales support, while the associated enterprise owned the key intangibles, assets, and risk-bearing functions. Because the assessee lacked the proprietary knowledge and resources to independently render the services, and the contractual risks remained with the associated enterprise, it was characterised as a limited-risk service provider. Its consistent TNMM benchmarking, accepted in the preceding year, could not be displaced merely due to non-filing of parent contracts where confidentiality concerns existed and the DRP had already directed reconsideration of the evidence. Case-Laws Income Tax Wed, 06 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791350