https://www.taxtmi.com/caselaws?id=793225 Transfer-pricing adjustments on intra-group management services were deleted because the services were evidenced and a nil valuation under CUP could not be sustained mechanically. Royalty disallowance was only partly rejected: the Tribunal accepted that royalty could not be wholly disallowed and allowed it at 5% on sales to associated enterprises and third parties. Interest on outstanding receivables was also deleted, as receivables had to be tested only after giving working capital adjustment and could not be benchmarked in isolation. Employees' contribution to PF and ESI deposited after the statutory due date was disallowed and upheld under Checkmate Services, resulting in partial relief overall. en-us Wed, 03 Jun 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793225 Transfer-pricing adjustments on intra-group management services were deleted because the services were evidenced and a nil valuation under CUP could not be sustained mechanically. Royalty disallowance was only partly rejected: the Tribunal accepted that royalty could not be wholly disallowed and allowed it at 5% on sales to associated enterprises and third parties. Interest on outstanding receivables was also deleted, as receivables had to be tested only after giving working capital adjustment and could not be benchmarked in isolation. Employees' contribution to PF and ESI deposited after the statutory due date was disallowed and upheld under Checkmate Services, resulting in partial relief overall. Case-Laws Income Tax Wed, 03 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793225