https://www.taxtmi.com/caselaws?id=801782 Rule 10CA deems an actual royalty price within the 35th-to-65th-percentile arm's-length range to be the arm's-length price; the median applies only if the actual price falls outside that range. Intra-group service charges require review of business need, actual rendition, expected commercial benefit, duplication, shareholder activity and a statutory pricing exercise supported by objective economic material. Operational records, service evidence and reliable allocation keys may establish genuine business services, while a nil price cannot rest solely on subjective views of commercial necessity after rejecting TNMM. Separately, deductibility of service expenditure depends on genuine, wholly and exclusively business use; commercial expediency is not displaced because the Revenue considers alternatives preferable. en-us Mon, 05 Oct 2026 00:00:00 +0530 Tue, 27 Oct 2026 08:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801782 Rule 10CA deems an actual royalty price within the 35th-to-65th-percentile arm's-length range to be the arm's-length price; the median applies only if the actual price falls outside that range. Intra-group service charges require review of business need, actual rendition, expected commercial benefit, duplication, shareholder activity and a statutory pricing exercise supported by objective economic material. Operational records, service evidence and reliable allocation keys may establish genuine business services, while a nil price cannot rest solely on subjective views of commercial necessity after rejecting TNMM. Separately, deductibility of service expenditure depends on genuine, wholly and exclusively business use; commercial expediency is not displaced because the Revenue considers alternatives preferable. Case-Laws Income Tax Mon, 05 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801782