https://www.taxtmi.com/caselaws?id=469249 Transfer pricing adjustments for intra-group services, including administrative, treasury, training, brokerage, other services and software sharing, were challenged on the ground that the services were treated as nil value based on duplication, incidental benefit and absence of tangible benefit. The record also included additional evidence and a remand report, but the lower analysis was found to have applied benefit-based reasoning and comparables without proper examination, so the matter was remitted for fresh adjudication. Depreciation on goodwill arising from amalgamation was also claimed through a revised return and was linked to consistency with later years; this issue too was sent back for fresh consideration by the AO in accordance with law. en-us Mon, 18 May 2020 00:00:00 +0530 Thu, 11 Jun 2026 14:47:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469249 Transfer pricing adjustments for intra-group services, including administrative, treasury, training, brokerage, other services and software sharing, were challenged on the ground that the services were treated as nil value based on duplication, incidental benefit and absence of tangible benefit. The record also included additional evidence and a remand report, but the lower analysis was found to have applied benefit-based reasoning and comparables without proper examination, so the matter was remitted for fresh adjudication. Depreciation on goodwill arising from amalgamation was also claimed through a revised return and was linked to consistency with later years; this issue too was sent back for fresh consideration by the AO in accordance with law. Case-Laws Income Tax Mon, 18 May 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469249