https://www.taxtmi.com/caselaws?id=793344 Expenditure on intra-group second line support services covered by a binding advance pricing agreement (APA) cannot be disallowed for lack of business expediency under section 37(1). The APA examined the functions performed, assets employed, risks assumed, pricing methodology and cost allocation, and treated the transaction as undertaken for business purposes. Its binding effect under section 92CC prevents a separate section 37(1) disallowance that would negate the accepted business character of the transaction. Acceptance of the claim in earlier and later years also supported consistency. The disallowance and related addition were deleted. 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 Expenditure on intra-group second line support services covered by a binding advance pricing agreement (APA) cannot be disallowed for lack of business expediency under section 37(1). The APA examined the functions performed, assets employed, risks assumed, pricing methodology and cost allocation, and treated the transaction as undertaken for business purposes. Its binding effect under section 92CC prevents a separate section 37(1) disallowance that would negate the accepted business character of the transaction. Acceptance of the claim in earlier and later years also supported consistency. The disallowance and related addition were deleted. Case-Laws Income Tax Fri, 22 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793344