https://www.taxtmi.com/caselaws?id=795706 Consistent acceptance of an arm's-length transfer-pricing method requires a cogent basis for departure and reliable comparable transactions meeting product, market, functional and remuneration comparability standards. Intra-group service charges, including the mark-up on third-party IT support costs, were treated as arm's length based on unchanged facts and prior-year acceptance. Marketing support services were benchmarked under the consistently accepted Transactional Net Margin Method because the Comparable Uncontrolled Price method lacked reliable comparability. Employee ESI contribution disallowance required challan verification, and set-off of brought-forward losses required fresh factual examination under law. en-us Wed, 22 Jul 2026 00:00:00 +0530 Sat, 25 Jul 2026 08:54:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795706 Consistent acceptance of an arm's-length transfer-pricing method requires a cogent basis for departure and reliable comparable transactions meeting product, market, functional and remuneration comparability standards. Intra-group service charges, including the mark-up on third-party IT support costs, were treated as arm's length based on unchanged facts and prior-year acceptance. Marketing support services were benchmarked under the consistently accepted Transactional Net Margin Method because the Comparable Uncontrolled Price method lacked reliable comparability. Employee ESI contribution disallowance required challan verification, and set-off of brought-forward losses required fresh factual examination under law. Case-Laws Income Tax Wed, 22 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795706