https://www.taxtmi.com/caselaws?id=469197 Contemporaneous evidence of invoices, e-mails and TDS support for intra-group services meant the management charges could not be disallowed on a mere benefit test, and the disallowance was deleted. Royalty payments were not liable to full disallowance where the assessee had paid royalty in earlier years and was not correctly treated as a contract manufacturer; the adjustment was restricted to allowing royalty at 5% on all sales. Outstanding receivables had to be tested after granting working capital adjustment, and the matter was remanded for fresh transfer pricing determination on that basis. en-us Wed, 07 May 2025 00:00:00 +0530 Tue, 09 Jun 2026 20:44:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469197 Contemporaneous evidence of invoices, e-mails and TDS support for intra-group services meant the management charges could not be disallowed on a mere benefit test, and the disallowance was deleted. Royalty payments were not liable to full disallowance where the assessee had paid royalty in earlier years and was not correctly treated as a contract manufacturer; the adjustment was restricted to allowing royalty at 5% on all sales. Outstanding receivables had to be tested after granting working capital adjustment, and the matter was remanded for fresh transfer pricing determination on that basis. Case-Laws Income Tax Wed, 07 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469197