https://www.taxtmi.com/caselaws?id=799205 Intra-group management and IT support charges require a verifiable arm's length price analysis based on debit notes, allocation keys, allocation workings and supporting evidence; the determination requires fresh examination. Benchmarking of imported and manufactured finished-goods transactions must rely on reliable comparable data and substantiated segmental results. Where manufacturing operations, capacity constraints, imported procurement and fixed customer prices make separate segment benchmarking unreliable, the interlinked transactions require entity-level benchmarking under an appropriate transfer-pricing method. Agronomy expenditure remains allowable as revenue expenditure, consistently with earlier accepted decisions. en-us Wed, 15 Jul 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799205 Intra-group management and IT support charges require a verifiable arm's length price analysis based on debit notes, allocation keys, allocation workings and supporting evidence; the determination requires fresh examination. Benchmarking of imported and manufactured finished-goods transactions must rely on reliable comparable data and substantiated segmental results. Where manufacturing operations, capacity constraints, imported procurement and fixed customer prices make separate segment benchmarking unreliable, the interlinked transactions require entity-level benchmarking under an appropriate transfer-pricing method. Agronomy expenditure remains allowable as revenue expenditure, consistently with earlier accepted decisions. Case-Laws Income Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799205