https://www.taxtmi.com/caselaws?id=800884 APA methodology for administrative support services may guide arm's-length benchmarking in a year outside the APA and rollback periods when it covers the same international transaction and the functional, asset and risk profile and activities remain unchanged. Uniform allocation of actual costs without mark-up, supported by consistent group-wide allocation, supports that approach. An arm's-length price cannot be set at nil on an ad hoc basis after rejecting taxpayer benchmarking; the proposed Other Method must be properly applied and quantified. On these principles, no transfer-pricing adjustment arises for the service charges. en-us Mon, 21 Sep 2026 00:00:00 +0530 Tue, 13 Oct 2026 07:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800884 APA methodology for administrative support services may guide arm's-length benchmarking in a year outside the APA and rollback periods when it covers the same international transaction and the functional, asset and risk profile and activities remain unchanged. Uniform allocation of actual costs without mark-up, supported by consistent group-wide allocation, supports that approach. An arm's-length price cannot be set at nil on an ad hoc basis after rejecting taxpayer benchmarking; the proposed Other Method must be properly applied and quantified. On these principles, no transfer-pricing adjustment arises for the service charges. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800884