https://www.taxtmi.com/caselaws?id=798565 Transactional Net Margin Method applies to bundled intra-group management and IT services where receipt, commercial benefit and non-duplication are established; a joint-venture partner's approval of another amount does not justify using the Comparable Uncontrolled Price Method, and the related transfer-pricing adjustments were deleted. Arm's length interest on external commercial borrowings requires fresh determination under the statutory transfer-pricing framework. Site-restoration costs incurred to meet a contractual restoration obligation remain deductible as revenue expenditure despite being debited against an existing decommissioning provision. Interest for advance-tax default is not chargeable to the extent tax deducted at source by the resident payer covers the taxpayer's total liability. en-us Fri, 14 Aug 2026 00:00:00 +0530 Wed, 09 Sep 2026 08:20:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798565 Transactional Net Margin Method applies to bundled intra-group management and IT services where receipt, commercial benefit and non-duplication are established; a joint-venture partner's approval of another amount does not justify using the Comparable Uncontrolled Price Method, and the related transfer-pricing adjustments were deleted. Arm's length interest on external commercial borrowings requires fresh determination under the statutory transfer-pricing framework. Site-restoration costs incurred to meet a contractual restoration obligation remain deductible as revenue expenditure despite being debited against an existing decommissioning provision. Interest for advance-tax default is not chargeable to the extent tax deducted at source by the resident payer covers the taxpayer's total liability. Case-Laws Income Tax Fri, 14 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798565