https://www.taxtmi.com/caselaws?id=794788 In transfer pricing, the arm's length price of a market study payment to an associated enterprise cannot be fixed at nil merely because the authority views the expenditure as generic, unnecessary, or insufficiently beneficial. The Tribunal held that the transfer pricing function is limited to benchmarking under Chapter X and Rules 10A to 10E, not assessing commercial expediency. It also noted evidence of subsequent investment and sales growth in Turkey supporting the business purpose of the study. A nil valuation without independent benchmarking was therefore treated as an impermissible disallowance on business-expenditure grounds, and the transfer pricing adjustment was deleted. en-us Fri, 23 Jan 2026 00:00:00 +0530 Sat, 11 Jul 2026 08:46:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794788 In transfer pricing, the arm's length price of a market study payment to an associated enterprise cannot be fixed at nil merely because the authority views the expenditure as generic, unnecessary, or insufficiently beneficial. The Tribunal held that the transfer pricing function is limited to benchmarking under Chapter X and Rules 10A to 10E, not assessing commercial expediency. It also noted evidence of subsequent investment and sales growth in Turkey supporting the business purpose of the study. A nil valuation without independent benchmarking was therefore treated as an impermissible disallowance on business-expenditure grounds, and the transfer pricing adjustment was deleted. Case-Laws Income Tax Fri, 23 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794788