https://www.taxtmi.com/caselaws?id=793159 Arm's length price for management, testing and validation services could not be fixed at nil where the assessee's aggregated TNMM benchmarking showed a higher operating margin, services were received, and no comparable uncontrolled transaction was brought on record; the transfer pricing adjustment was deleted. Notional interest on outstanding receivables from associated enterprises was also disallowed as a separate adjustment because the receivables were closely linked to the main transaction, already covered by TNMM and working capital adjustment, and no duplication was permitted; the addition was deleted. The section 43B payment-basis disallowance was rejected because it had not arisen in the assessment or DRP proceedings and was not within the appeal. en-us Tue, 28 Apr 2026 00:00:00 +0530 Wed, 10 Jun 2026 07:26:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793159 Arm's length price for management, testing and validation services could not be fixed at nil where the assessee's aggregated TNMM benchmarking showed a higher operating margin, services were received, and no comparable uncontrolled transaction was brought on record; the transfer pricing adjustment was deleted. Notional interest on outstanding receivables from associated enterprises was also disallowed as a separate adjustment because the receivables were closely linked to the main transaction, already covered by TNMM and working capital adjustment, and no duplication was permitted; the addition was deleted. The section 43B payment-basis disallowance was rejected because it had not arisen in the assessment or DRP proceedings and was not within the appeal. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793159