Transfer pricing consistency under TNMM protects integrated intra-group service benchmarking where facts and business model remain unchanged.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Intra-group services closely linked to core business operations may be benchmarked together under TNMM; where facts and the business model remain unchanged, earlier transfer-pricing treatment should be followed despite pending departmental appeals. The related transfer-pricing adjustments and connected branch-office expenditure and depreciation/depletion disallowances were accordingly deleted or allowed. Arm's-length interest on external commercial borrowings required fresh determination by the AO/TPO. Site-restoration costs incurred to discharge a contractual decommissioning obligation were allowable business expenditure despite utilisation of a provision. Refund interest depended on verification of issuance and encashment; TDS credit requ.........