https://www.taxtmi.com/caselaws?id=799206 Management and technical fees paid to an associated enterprise cannot be assigned a nil arm's length price where evidence establishes that intra-group services were received and costs were allocated reasonably on a cost-to-cost basis. The benefit test does not require immediate measurable results, and transfer-pricing authorities cannot substitute their business judgment for commercial expediency; the related adjustment was deleted. Interest on outstanding associated-enterprise trade receivables must be recomputed at LIBOR plus 200 basis points after allowing a 60-day credit period. en-us Fri, 17 Jul 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799206 Management and technical fees paid to an associated enterprise cannot be assigned a nil arm's length price where evidence establishes that intra-group services were received and costs were allocated reasonably on a cost-to-cost basis. The benefit test does not require immediate measurable results, and transfer-pricing authorities cannot substitute their business judgment for commercial expediency; the related adjustment was deleted. Interest on outstanding associated-enterprise trade receivables must be recomputed at LIBOR plus 200 basis points after allowing a 60-day credit period. Case-Laws Income Tax Fri, 17 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799206