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“intra group services”

Transfer PricingSection 92BSection 92B165 judgments

OSG (INDIA) PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-3(1), GURGAON

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4925/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)Section 144B

after going through all the facts of the case issued a show cause notice dated 13.10.2023 to the assessee on the issue of Intra group services (Management Fees) of Rs. 27,89,936/-. ITA No.- 4925/Del/2024 OSG (India) Pvt. Ltd. 3.4 Further the TPO noted that assessee had failed ... Year 2003-04 [TS-100-ITAT-2010(Bang)], which inter-alia held that to satisfy the arm's length standard, a charge for intra group services or intangibles must at least meet the following conditions The intragroup services or intangibles have actually been received The need for intra group services

COMPASS INDIA SUPPORT SERVICES PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

ITA 511/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18
Section 143(3)

services, please provide the following\ndetails.\n4.1. Details and documentary evidence of the amount (this shall include the break-up)\npaid for the Intra-Group Services rendered by the Non-Resident AE during the A.Y.\nconcerned.\n4.2. A copy of the agreement(s) executed in between your company ... Resident\nAE (s) in regards to the Intra-Group service(s) rendered by the AE for the A.Y.\nconcerned. In case any addendum to the agreement exists, you have to provide a copy\nof that as well.\n4.3. Details and documentary evidence of cost incurred by the Non-Resident

COMPASS INDIA SUPPORT SERVICES PRIVATE LTD. ,GURGAON vs. DCIT, CIRCLE-4(2), DELHI

ITA 1383/DEL/2022[2018-19]Status: DisposedITAT Delhi04 Feb 2026AY 2018-19
Section 143(3)

services, please provide the following\ndetails.\n4.1. Details and documentary evidence of the amount (this shall include the break-up)\npaid for the Intra-Group Services rendered by the Non-Resident AE during the A.Y.\nconcerned.\n4.2. A copy of the agreement(s) executed in between your company ... Resident\nAE (s) in regards to the Intra-Group service(s) rendered by the AE for the A.Y.\nconcerned. In case any addendum to the agreement exists, you have to provide a copy\nof that as well.\n4.3. Details and documentary evidence of cost incurred by the Non-Resident

DEPUTY COMMISSIONER OF INCOME TAX 1(1)(2), MUMBAI vs. HINDUSTAN UNILEVER LIMITED, MUMBAI

ITA 929/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05
For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80H

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“H” BENCH, MUMBAI\nBEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER\nSHRI

HINDUSTAN UNILEVER LIMITED,MUMBAI vs. DY.CIT-1(1)(2), MUMBAI

ITA 1041/MUM/2018[2004-05]Status: DisposedITAT Mumbai30 Jan 2026AY 2004-05
For Appellant: Shri Nishant ThakkarFor Respondent: Shri Ajay Chandra, CIT-DR
Section 10BSection 145ASection 14ASection 250Section 80Section 801BSection 80H

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“H” BENCH, MUMBAI\nBEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER\nSHRI

GIESECKE AND DEVRIENT INDIA PVT LTD.,GURGAON vs. ACIT (OSD), NEW DELHI

In the result, assessee’s appeal in ITA No

ITA 1428/DEL/2022[2018-19]Status: DisposedITAT Delhi07 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Smt. Renu Jauhriassessment Year: 2018-19

Section 119Section 143(3)Section 144BSection 144B(8)Section 144C(13)Section 144C(5)

transaction pertaining to provision of ITeS segment and in complete ignorance of the data available as per audited financials of the comparables. C Intra-Group Services [INR 11,80,91,036/- 26. That the Ld. TPO/AO/ DRP grossly erred in facts and in law in rejecting the economic analysis ... 166/Del/2022 b. there is no basis for revenue claimed to have been generated from the alleged services: c. cost allocation for the intra group services has no basis nor has any such basis been given for each intra-group services received; d. CUP has been correctly applied

DCIT, NEW DELHI vs. M/S. EXXON MOBIL LUBRICANTS PVT. LTD., NEW DELHI

In the result, appeal of the Revenue is party allowed

ITA 1348/DEL/2012[2005-06]Status: DisposedITAT Delhi07 Jan 2026AY 2005-06
Section 143(2)Section 143(3)Section 250(6)Section 92C

accord\nan opportunity to the assessee since such a requirement has not been adhered\nby the TPO in respect of international transaction of intra group services\nreceived by the Respondent, the impugned order of the TPO was bad in law and\nliable to be set aside. Reliance in this regard ... Further, in Respondent's own case for AY 2007-08, CIT(A) has accepted the\narm's length of intra-group services pertaining to (i) corporate law, (ii) Security,\n(ii) Safety Health Environment, (iv) Treasury, (v) Business Advisory and (vi)\nInformation Technology (partly)\n9. Heard both the parties

SRF LIMITED,DELHI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 10(1), NEW DELHI, DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

transaction of reimbursement/recovery of expenses, the Ld. DRP and consequently Ld. TPO / Ld. AO have erred in law treating the abovementioned transaction as intra-group services and applying mark-up @ 9.26% based on the search process. 23.0 That without prejudice, the Ld. DRP and consequently Ld. TPO / Ld. AO have ... ITAT may be pleased to treat the above transactions in the nature of pure reimbursement and not in the nature of intra-group services and thus warranting no mark-up over and above cost. IV. Corporate Guarantee Fee from AE’s - Adjustment of Rs. 2,03,99,088/- 26.0 That

SRF LIMITED ,DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

transaction of reimbursement/recovery of expenses, the Ld. DRP and consequently Ld. TPO / Ld. AO have erred in law treating the abovementioned transaction as intra-group services and applying mark-up @ 9.26% based on the search process. 23.0 That without prejudice, the Ld. DRP and consequently Ld. TPO / Ld. AO have ... ITAT may be pleased to treat the above transactions in the nature of pure reimbursement and not in the nature of intra-group services and thus warranting no mark-up over and above cost. IV. Corporate Guarantee Fee from AE’s - Adjustment of Rs. 2,03,99,088/- 26.0 That

SRF LIMITED,NEW DELHI vs. ACIT, CIRCLE-10(1), DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

transaction of reimbursement/recovery of expenses, the Ld. DRP and consequently Ld. TPO / Ld. AO have erred in law treating the abovementioned transaction as intra-group services and applying mark-up @ 9.26% based on the search process. 23.0 That without prejudice, the Ld. DRP and consequently Ld. TPO / Ld. AO have ... ITAT may be pleased to treat the above transactions in the nature of pure reimbursement and not in the nature of intra-group services and thus warranting no mark-up over and above cost. IV. Corporate Guarantee Fee from AE’s - Adjustment of Rs. 2,03,99,088/- 26.0 That

KANTAR ANALYTICS INDIA PRIVATE LIMITED (FORMERLY KNOWN AS FIREFLY MARKET RESERCH INDIA PRIVATE LIMITED (SUCCESSOR OF ANALYTICS QUOTIENT SERVICE INDIA PRIVATE LIMITED),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21
Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

well as the Indian safe-harbour\nregulations may be of relevance.\nParagraph 7.45 of the OECD Guidelines define the Low Value adding Intra Group Services\n('LVIGS') as services performed by one member or more than one member of an MNE group on\nbehalf of one or more other group ... Under rule 10TA of the Income Tax Rules, the definition of LVIGS in clause\n(ga) is as follows:\n\"low value-adding intra-group services\" means services that are performed by one or more members\nof a multinational enterprise group on behalf of one or more other members

LINTAS INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT, CIRCLE 16(1), MUMBAI

The appeal of the assessee is partly allowed for statistical purposes

ITA 5889/MUM/2024[2021-22]Status: DisposedITAT Mumbai19 Nov 2025AY 2021-22

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

For Appellant: Shri Ajit Jain, Ld. A.RFor Respondent: Shri Kiran Unavekar, Ld. Sr. D.R
Section 144Section 144CSection 144C(5)Section 92C

facts and circumstances of the case. During the year under consideration. the assessee has paid to the AE on account of intra group services (IGS). The intra group services are broadly divided into the following categories: 1) Fees paid pursuant to Global Information Service (GIS) Agreement 2) Fees paid pursuant ... course of hearing before us. During the year under consideration, the assessee has paid to its Associated Enterprises (AEs) on account of intra-group services. The intra group services are broadly divided into the following categories as mentioned below: Payment of Global Information Services Rs.6,58,85,932 The Services

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

In the result, appeal filed by the assessee is partly\nallowed for statistical purposes

ITA 1778/PUN/2024[AY 2020-21]Status: DisposedITAT Pune14 Nov 2025
Section 144Section 144CSection 144C(8)Section 153Section 92CSection 92D

Appellant's\nincome in connection with payment by the Appellant to its\nAssociated Enterprises ('AEs'), for availing intra group services and\nthereby determining a total income of INR 5,66,75,610 in the order\ndated 27 June 2024.\n7. Upholding/confirming the action of Ld. TPO, by determining\nthe ... that there are certain\ninternational transactions entered into by the assessee\nnamely 'Payment of Royalty for Trademark at\nRs.1,35,33,495/- and Intra Group Services availed from AE'\nat Rs.5,66,05,177/-. Ld. AO made a reference to the Transfer\nPricing Officer (TPO) u/s.92CA

PRECISION CAMSHAFTS LIMITED,PUNE vs. DCIT CIRCLE 1, SOLAPUR

In the result, appeal of the assessee is partly allowed

ITA 2744/PUN/2024[2021-22]Status: DisposedITAT Pune12 Nov 2025AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2744/Pun/2024 निर्धारण वषा / Assessment Year: 2021-22 Precision Camshafts Limited, V Assessment Unit, E-102/103, Akkalkot Road S Income Tax Department Midc, Solapur – 413006. (National Faceless Maharashtra. Assessment Center), Jurisdiction : Pne C(1), Range 63, Deputy Commissioner Of Income Tax („Dcit‟), Circle-1, Solapur. Pan: Aabcp1086B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S Pathak - Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 12/11/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Read With Section 144B Of The Act, 1961 Dated 24.10.2024 For A.Y.2021-22 Emanating From Dispute Resolution Panel‟S Order Passed Under Section 144C(5) Of

Section 143(3)Section 144BSection 144C(1)Section 144C(5)Section 153Section 92B

आयकर अपीलीय अधिकरण ”सी” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “C” :: PUNE BEFORE SHRI RAMA KANTA

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 2321/DEL/2022[2018-19]Status: DisposedITAT Delhi10 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(2)Section 144C(13)Section 144C(5)Section 147Section 92C

Panel agrees with the view of the TPO that in order to examine the arm's length price of intra group services received by one of the associated enterprises following essential information should be available : 1. Whether the assessee has received intra group services? 2. What are the economic ... commercial benefits derived by the recipient of intra group services? 3. In order to identify the charges relating to services, there should be a mechanism. in place which can identify (i) the cost incurred by the AE in providing the intra group services and (ii) the basis of all allocation

CPPGROUP SERVICES LIMITED,LEEDS, UNITED KINGDOM vs. ASSISTANT COMMISSIONER OF INCOME-TAX, DELHI

In the result, the appeal of the assessee is party allowed

ITA 980/DEL/2025[2022-23]Status: DisposedITAT Delhi04 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh[Assessment Year: 2022-23]

Section 143(3)Section 234B

global scale.” 4.7. According to the Assessing Officer as noted in para 7.2 that the assessee company is providing a host of Intra Group Services which services and tax services etc. to Indian entity on a long-term basis so that it can carry out the business functions

MICHAEL PAGE INTERNATIONAL RECRUITMENT PVT LTD,MUMBAI vs. DCIT CIRCLE 14(1)(1), MUMBAI

ITA 6748/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-22
Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 37Section 41

relation to the\ninternational transactions pertaining to payment for availing of\nbusiness support services and business technology services ('together\nto be known as 'Intra group services' or 'IGS').\nGround No.4: General Ground\nOn the facts and in the circumstances of the case and in law, the Ld.\nAO erred ... that services were actually provided to\nthe Appellant.\nThe Appellant humbly prays that the Ld. AO be directed to delete the\ndisallowance of intra group services charges in full.\nGround No.7: TP adjustment on account of IGS\nRs.19,42,69,527:\nOn the facts and in the circumstances

SCHNEIDER ELECTRIC PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 22(2), C. R. BUILDING,DELHI

The appeal is allowed partly

ITA 5589/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2021-22 Schneider Electric Private Vs Dcit, Limited, Circle 22(2), C-56, Mayapuri Industrial Area, Delhi. Phase-2, West Delhi, Delhi – 110 064. Pan: Abacs1671F (Appellant) (Respondent) Assessee By : Shri Rohit Tiwari, Advocate & Ms Tanya, Advocate. Revenue By : Shri S.K. Jadhav, Cit-Dr Date Of Hearing : 20.08.2025 Date Of Pronouncement : 15.10.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Final Assessment Order Dated 28.10.2024 Passed By The Assessment Unit, Income-Tax Department (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For Ay 2021-22. 2. Heard & Perused The Records. On The Basis Of Submission & Material On Record It Comes Up That Assesse/ Appellant (Sepl) Was Incorporated In 2018 As A Subsidiary Of Schneider Electric Industries Sas (A Wholly Owned Subsidiary Of Schneider Electric Se) & Belgium. It Is A Private Limited Company

For Appellant: Shri Rohit Tiwari, Advocate &For Respondent: Shri S.K. Jadhav, CIT-DR
Section 143(3)

services (“TNMM”) (“OP/OC”) 22.10% to Provision of Contract and 2 TNMM OP/OC 12.23% 51,17,20,000 R&D services 28.14% Comparable 3 Intra Group Services (IGS) Uncontrolled Price Not Applicable (“N.A”) 30,03,50,226 (“CUP”) Method 4 Outstanding Trade receivable Other Method N.A 84,45,297 Total adjustment ... adjustments. 6. Ground no, 3 with sub-grounds refer to enhancing the income by Rs. 30,03,50,226 in relation to intra group services fees paid by the Appellant to its AEs by rejecting the TP documentation maintained by the Appellant and determining arm’s length price

M/S. PHILIPS INDIA LTD.,KOLKATA vs. DCIT, CIRCLE - 11(1), KOLKATA

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 2610/KOL/2024[2021-2022]Status: DisposedITAT Kolkata26 Aug 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm M/S Philips India Limited Rajarhat 4A, 5Th Floor, Ecospace The Dcit Business Park, Premises A4 Ii, Circle 11(1), Aayakar Bhavan, New Town, Chakpachuria, P-7, Chowringhee Square, Vs. Kolkata-700156 Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri Praveen Kishore, Cit Dr Date Of Hearing: 23.07.2025 Date Of Pronouncement: 26.08.2025

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri Praveen Kishore, CIT DR

allowed. 4. The issue raised in ground no.3 is in respect of transfer pricing adjustment of ₹108,79,48,589/- on account of Intra Group Services (IGS) received by the assessee. 4.1. At the outset, the ld. Counsel for the assessee submitted that the issue has been decided in assessee ... under: - “011. The issue raised in ground no.3 is against the transfer pricing adjustment of ₹108,79,48,589/- on account of Intra Group Services (‘IGS’) received by the assessee. 012. We note that this is a recurring issue in the case of the assessee which has been decided

RUBICON RESEARCH LIMITED (FORMERLY KNOWN AS RUBICON RESEARCH PRIVATE LIMITED),THANE, MAHARASHTRA vs. DEPUTY COMMISSIONER OF INCOME TAX - CIRCLE 15(3)(1), MUMBAI

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6647/MUM/2024[2021-22]Status: DisposedITAT Mumbai18 Aug 2025AY 2021-22

Bench: Smt. Beena Pillai & Smt. Renu Jauhriआयकर अपील सं./Ita No.6647/Mum/2024 (निर्धारण वर्ा/Assessment Year: 2021-22) Rubicon Research V/S. Deputy Commissioner Of Limited (Formerly बिधम Income Tax- Circle Known As Rubicon 15(3)(1), Mumbai Research Private Aaykar Bhavan, Maharshi Limited) Karve Road, New Marine Medone House, B-75, Lines, Churchgate, Mumbai Road No. 33, Wagle 400020 Estate, Thane 400604. Assessment Unit, National Faceless Assessment Centre Income Tax Department, Ministry Of Finance Delhi स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcr1422M Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी निर्ााररती की ओर से /Assessee By: Shri. Darpan Kirpalani रधजस्व की ओर से /Revenue By: Shri. Asif Karmali (Sr Dr)

For Appellant: Shri. Darpan KirpalaniFor Respondent: Shri. Asif Karmali (SR DR)
Section 143(3)Section 153Section 234BSection 37Section 92CSection 92C(3)Section 92D

questioned the very base of the IGS rendered and not the mark up as such. Global TP guidelines enunciate that the intra group services should be delientaed and proper FAR analysis conducted to benchmark the transaction using the appropriate methods. The basic principles emanating from the various judicial decisions regarding ... transactions, aggregation approach (under TNMM) could be discarded, and the transactions could be benchmarked separately. • The fact that the assessee was availing the intra-group services in the past as well without making any payment indicates that payments are not for actual services rendered nor for any additional benefit

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