https://www.taxtmi.com/caselaws?id=470159 A nil arm's length price for management support services cannot be sustained where the service cost forms part of the accepted cost base under a cost-plus model. The transactional net margin method and the operating margin for the information-technology enabled services segment were accepted, with the management-support cost included in that base. Determining the service value at nil without functional, asset and risk analysis was impermissible. Excluding the cost would also reduce revenue recoverable from the associated enterprise and lower taxable income; therefore, section 92(3) barred the adjustment. The nil arm's length price adjustment was deleted. en-us Fri, 31 Jan 2025 00:00:00 +0530 Fri, 17 Jul 2026 21:38:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470159 A nil arm's length price for management support services cannot be sustained where the service cost forms part of the accepted cost base under a cost-plus model. The transactional net margin method and the operating margin for the information-technology enabled services segment were accepted, with the management-support cost included in that base. Determining the service value at nil without functional, asset and risk analysis was impermissible. Excluding the cost would also reduce revenue recoverable from the associated enterprise and lower taxable income; therefore, section 92(3) barred the adjustment. The nil arm's length price adjustment was deleted. Case-Laws Income Tax Fri, 31 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470159