https://www.taxtmi.com/highlights?id=102246 Closely linked international transactions benchmarked together under TNMM should not be selectively segregated for separate testing where the aggregated approach has been accepted for other transactions. Intra-group service payments require evidence of services and benefits, and their arm's length price cannot be treated as nil under CUP without a comparable uncontrolled transaction. The notes also address deletion of a fixed-asset purchase mark-up adjustment through consistency with an earlier year. The dividend distribution tax treaty-rate claim was remitted pending resolution of the underlying legal issue. An additional refund claim may be raised before appellate authorities without filing a revised return, for determination of correct tax liability. en-us Fri, 31 Jul 2026 12:56:49 +0530 Fri, 31 Jul 2026 12:56:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102246 Closely linked international transactions benchmarked together under TNMM should not be selectively segregated for separate testing where the aggregated approach has been accepted for other transactions. Intra-group service payments require evidence of services and benefits, and their arm's length price cannot be treated as nil under CUP without a comparable uncontrolled transaction. The notes also address deletion of a fixed-asset purchase mark-up adjustment through consistency with an earlier year. The dividend distribution tax treaty-rate claim was remitted pending resolution of the underlying legal issue. An additional refund claim may be raised before appellate authorities without filing a revised return, for determination of correct tax liability. Highlights Income Tax Fri, 31 Jul 2026 12:56:49 +0530 https://www.taxtmi.com/highlights?id=102246