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Management Support Services vis-à-vis Intra Group Services – An Analysis under Transfer Pricing - Part III
Introduction:
In previous parts of Article (Part I[1] and Part II[2]), the concept of taxability of management support services under treaty and Income Tax Act (‘IT Act’) has been analysed in detail. Previous Parts of Article deal with taxability of such services in India in the hands of recipient.
However, the issue may not be said completely analyzed, without analyzing the deductibility of such expenses in the hands of the payer from the standpoint of transfer pricing.
Let us proceed to continue with the same example considered in the previous parts.