https://www.taxtmi.com/caselaws?id=471759 Arm's length price of intra-group technical and stewardship service payments was sustained at nil because the taxpayer did not establish actual receipt or commercial benefit from the services. A broadly worded service agreement, without defined deliverables, cost-allocation methodology, performance benchmarks or validation mechanisms, did not substantiate the charges. General or post-period emails, brief managerial visits, and unsupported presentations or meeting notes were insufficient. Contemporaneous, verifiable evidence such as meeting records, training material, project documentation and identifiable service deliverables was required to demonstrate rendition and benefit of the intra-group services. en-us Wed, 09 Apr 2025 00:00:00 +0530 Wed, 16 Sep 2026 19:00:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471759 Arm's length price of intra-group technical and stewardship service payments was sustained at nil because the taxpayer did not establish actual receipt or commercial benefit from the services. A broadly worded service agreement, without defined deliverables, cost-allocation methodology, performance benchmarks or validation mechanisms, did not substantiate the charges. General or post-period emails, brief managerial visits, and unsupported presentations or meeting notes were insufficient. Contemporaneous, verifiable evidence such as meeting records, training material, project documentation and identifiable service deliverables was required to demonstrate rendition and benefit of the intra-group services. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471759