https://www.taxtmi.com/caselaws?id=796088 The note discusses transfer-pricing treatment of closely linked intra-group services and fixed-asset purchases benchmarked under an aggregated Transactional Net Margin Method. It explains that selectively assigning a nil arm's length price under the Comparable Uncontrolled Price Method requires reliable comparable uncontrolled data, while evidence of services and benefits supports the taxpayer's position. It also addresses appellate admission of an additional treaty-based dividend distribution tax claim without a revised return, stating that appellate authorities may consider claims needed to determine correct tax liability, with the substantive treaty issue awaiting final legal determination. 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 The note discusses transfer-pricing treatment of closely linked intra-group services and fixed-asset purchases benchmarked under an aggregated Transactional Net Margin Method. It explains that selectively assigning a nil arm's length price under the Comparable Uncontrolled Price Method requires reliable comparable uncontrolled data, while evidence of services and benefits supports the taxpayer's position. It also addresses appellate admission of an additional treaty-based dividend distribution tax claim without a revised return, stating that appellate authorities may consider claims needed to determine correct tax liability, with the substantive treaty issue awaiting final legal determination. Case-Laws Income Tax Tue, 28 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796088