https://www.taxtmi.com/caselaws?id=794790 Transfer pricing adjustment for intra-group management fee was deleted because the assessee produced documentary evidence of actual services received and the group cost allocation basis. The ITAT held that revenue cannot nullify an international transaction merely by questioning commercial expediency, business necessity, or the assessee's commercial wisdom. Where services are shown to have been rendered, the arm's length price cannot be fixed at nil unless a legally permissible method is applied and it is demonstrated that comparable uncontrolled services would be available for nil consideration. en-us Mon, 25 May 2026 00:00:00 +0530 Sat, 11 Jul 2026 08:46:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794790 Transfer pricing adjustment for intra-group management fee was deleted because the assessee produced documentary evidence of actual services received and the group cost allocation basis. The ITAT held that revenue cannot nullify an international transaction merely by questioning commercial expediency, business necessity, or the assessee's commercial wisdom. Where services are shown to have been rendered, the arm's length price cannot be fixed at nil unless a legally permissible method is applied and it is demonstrated that comparable uncontrolled services would be available for nil consideration. Case-Laws Income Tax Mon, 25 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794790