https://www.taxtmi.com/caselaws?id=793344 A binding advance pricing agreement covering intra-group second line support services under section 92CC was treated as conclusive for the transaction's business character and pricing framework. Where the services and their cost allocation fell within the APA, a separate disallowance under section 37(1) on the ground of lack of business expediency was said to be unsustainable. The note also records that conformity of the revised return with the APA and consistency with acceptance in earlier and later years supported the same view, resulting in deletion of the disallowance relating to the support services. en-us Fri, 22 May 2026 00:00:00 +0530 Sat, 13 Jun 2026 08:36:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793344 A binding advance pricing agreement covering intra-group second line support services under section 92CC was treated as conclusive for the transaction's business character and pricing framework. Where the services and their cost allocation fell within the APA, a separate disallowance under section 37(1) on the ground of lack of business expediency was said to be unsustainable. The note also records that conformity of the revised return with the APA and consistency with acceptance in earlier and later years supported the same view, resulting in deletion of the disallowance relating to the support services. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793344