India: Deduction of payments for intercompany advisory and business support services allowed (High Court decision)
Taxpayer sufficient documentary evidence that it received the services.
The Bombay High Court held that the taxpayer sufficiently proved it received advisory and business support services from its affiliated enterprise in accordance with the relevant intercompany agreement and thus rejected the tax authority’s disallowance of the taxpayer’s deduction for the payment of such services.
The court found that the taxpayer provided sufficient documentary evidence of the services provided, including e-mails and other supporting documents.
The case is: PCIT v. Grupo Antolin India Pvt Ltd
Read a November 2025 report prepared by the KPMG member firm in India