https://www.taxtmi.com/caselaws?id=796088 Transfer-pricing adjustments for intra-group services and fixed-asset purchases were deleted because closely linked international transactions had been benchmarked under an accepted aggregated Transactional Net Margin Method. Selectively segregating intra-group services and assigning a nil arm's length price under the Comparable Uncontrolled Price Method was unsustainable without reliable comparable uncontrolled transactions; evidence also established receipt of services and tangible benefits. Treaty-based relief for dividend distribution tax may be raised as an additional claim in appellate proceedings without filing a revised return where required to determine correct tax liability. The claim was admitted for fresh adjudication after final resolution of the pending substantive legal issue. en-us Tue, 28 Jul 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796088 Transfer-pricing adjustments for intra-group services and fixed-asset purchases were deleted because closely linked international transactions had been benchmarked under an accepted aggregated Transactional Net Margin Method. Selectively segregating intra-group services and assigning a nil arm's length price under the Comparable Uncontrolled Price Method was unsustainable without reliable comparable uncontrolled transactions; evidence also established receipt of services and tangible benefits. Treaty-based relief for dividend distribution tax may be raised as an additional claim in appellate proceedings without filing a revised return where required to determine correct tax liability. The claim was admitted for fresh adjudication after final resolution of the pending substantive legal issue. Case-Laws Income Tax Tue, 28 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796088