TP Adjustment - ALP determination - intra-group services - TPO...

TP Adjustment - ALP determination - intra-group services - TPO cannot stand in judgment on what benefits the assessee has derived from the services and assessee's obligation lies to the extent of demonstrating receipt of services. Once, the assessee has been able to demonstrate receipt of services, in our view, Transfer Pricing adjustment without applying any prescribed benchmarking method is unsustainable - AT