https://www.taxtmi.com/caselaws?id=471463 Arm's-length pricing of intra-group management support services requires application of the benefit test: services must be rendered and provide economic or commercial value, while shareholder and duplicative activities are not chargeable. Service agreements, cost-allocation workings, benchmarking support and functional material can establish rendition and benefit; acceptance of part of the payment further supports that conclusion. Inclusion in a TNMM cost base does not alone prove benefit but may corroborate operational use. A 5% mark-up on indirect costs within the comparable range was consistent with low value-adding intra-group service principles. Pricing the disputed services at nil was unsustainable, requiring deletion of the transfer-pricing adjustment. en-us Mon, 17 Nov 2025 00:00:00 +0530 Thu, 03 Sep 2026 13:57:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471463 Arm's-length pricing of intra-group management support services requires application of the benefit test: services must be rendered and provide economic or commercial value, while shareholder and duplicative activities are not chargeable. Service agreements, cost-allocation workings, benchmarking support and functional material can establish rendition and benefit; acceptance of part of the payment further supports that conclusion. Inclusion in a TNMM cost base does not alone prove benefit but may corroborate operational use. A 5% mark-up on indirect costs within the comparable range was consistent with low value-adding intra-group service principles. Pricing the disputed services at nil was unsustainable, requiring deletion of the transfer-pricing adjustment. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471463