https://www.taxtmi.com/caselaws?id=799126 Intra-group services' arm's length price must be determined using a prescribed transfer-pricing method and substantiated facts, rather than fixed at nil without adequate basis. Agreements, invoices, emails and an independent accountant's cost-allocation certificate supported the rendering of services. Where identical arrangements in earlier assessment years had been accepted and no distinguishing facts existed, pending departmental appeals against those earlier determinations did not displace their relevance. The arm's length price could not be determined at nil, and the transfer-pricing adjustment was deleted. en-us Thu, 23 Jul 2026 00:00:00 +0530 Thu, 17 Sep 2026 07:52:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799126 Intra-group services' arm's length price must be determined using a prescribed transfer-pricing method and substantiated facts, rather than fixed at nil without adequate basis. Agreements, invoices, emails and an independent accountant's cost-allocation certificate supported the rendering of services. Where identical arrangements in earlier assessment years had been accepted and no distinguishing facts existed, pending departmental appeals against those earlier determinations did not displace their relevance. The arm's length price could not be determined at nil, and the transfer-pricing adjustment was deleted. Case-Laws Income Tax Thu, 23 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799126