https://www.taxtmi.com/caselaws?id=800403 Intra-group services that are inextricably linked with other international transactions may be benchmarked on an aggregated basis under the Transactional Net Margin Method (TNMM). Section 92C(1) and Rule 10A(d) permit aggregation of closely linked transactions for determining the arm's length price. Service agreements and supporting material establishing the nature and economic value of services support this treatment, particularly where related manufacturing transactions have been accepted under aggregated TNMM and management-fee payments were similarly treated in earlier years. Separate benchmarking of those services at a nil arm's length price under the Other Method is inconsistent with the accepted aggregated approach. en-us Wed, 23 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800403 Intra-group services that are inextricably linked with other international transactions may be benchmarked on an aggregated basis under the Transactional Net Margin Method (TNMM). Section 92C(1) and Rule 10A(d) permit aggregation of closely linked transactions for determining the arm's length price. Service agreements and supporting material establishing the nature and economic value of services support this treatment, particularly where related manufacturing transactions have been accepted under aggregated TNMM and management-fee payments were similarly treated in earlier years. Separate benchmarking of those services at a nil arm's length price under the Other Method is inconsistent with the accepted aggregated approach. Case-Laws Income Tax Wed, 23 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800403