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    <title>2026 (6) TMI 38 - ITAT AHMEDABAD</title>
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    <description>Transfer pricing adjustment at nil for intra-group GHO non-IT services, GHO IT services and RHO services was held unsustainable because the revenue authorities did not conduct a proper benchmarking exercise under the prescribed methods. The Tribunal accepted the assessee&#039;s documentary evidence showing rendition of services and followed its own earlier orders for prior years, which had been affirmed by the High Court. It held that ALP could not be determined at nil merely on assertions that the services were duplicative, shareholder in nature, or that insufficient benefit was derived. The adjustment was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792657</link>
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