https://www.taxtmi.com/caselaws?id=470181 A nil arm's length price adjustment for management support services was unsustainable where the management fee formed part of the operating cost base for cost-plus billing to associated enterprises. Excluding that cost while retaining the accepted mark-up would proportionately reduce service revenue and operating profit, thereby reducing taxable income rather than increasing it. Transfer-pricing provisions cannot be applied where the arm's length computation reduces income chargeable to tax or increases loss. The adjustment was therefore deleted. en-us Mon, 17 Mar 2025 00:00:00 +0530 Sat, 18 Jul 2026 20:46:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470181 A nil arm's length price adjustment for management support services was unsustainable where the management fee formed part of the operating cost base for cost-plus billing to associated enterprises. Excluding that cost while retaining the accepted mark-up would proportionately reduce service revenue and operating profit, thereby reducing taxable income rather than increasing it. Transfer-pricing provisions cannot be applied where the arm's length computation reduces income chargeable to tax or increases loss. The adjustment was therefore deleted. Case-Laws Income Tax Mon, 17 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470181