https://www.taxtmi.com/caselaws?id=793221 Arm's length price cannot be fixed at nil on a pure benefit or necessity test where franchise fee reflects a composite contractual bundle of rights and services supported by the commercial arrangement and prior-year tribunal findings. Intra-group service payments similarly cannot be disallowed merely because the authorities consider the services unnecessary or insufficiently beneficial when contemporaneous agreements, invoices, service records, and allocation details show receipt. For purchase of goods, comparables may be excluded for filter failures, additional comparables may be examined afresh, and working capital adjustment must be considered in accordance with law. Once the transfer pricing additions fail, the related section 37(1) disallowance also falls away. en-us Wed, 20 May 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793221 Arm's length price cannot be fixed at nil on a pure benefit or necessity test where franchise fee reflects a composite contractual bundle of rights and services supported by the commercial arrangement and prior-year tribunal findings. Intra-group service payments similarly cannot be disallowed merely because the authorities consider the services unnecessary or insufficiently beneficial when contemporaneous agreements, invoices, service records, and allocation details show receipt. For purchase of goods, comparables may be excluded for filter failures, additional comparables may be examined afresh, and working capital adjustment must be considered in accordance with law. Once the transfer pricing additions fail, the related section 37(1) disallowance also falls away. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793221