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    <title>2022 (4) TMI 1012 - ITAT PUNE</title>
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    <description>The ITAT found that the Management Service Fee (MSF) paid to Associated Enterprises (AE) was at Arm&#039;s Length Price (ALP), supported by evidence of services provided. The TPO&#039;s determination of NIL value for the MSF transaction was deemed incorrect. The selection of Walter AG as the tested party was rejected, and the adequacy of documentation submitted by the assessee was upheld. The appeal was allowed, and the transfer pricing adjustment for the MSF was deleted.</description>
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      <description>The ITAT found that the Management Service Fee (MSF) paid to Associated Enterprises (AE) was at Arm&#039;s Length Price (ALP), supported by evidence of services provided. The TPO&#039;s determination of NIL value for the MSF transaction was deemed incorrect. The selection of Walter AG as the tested party was rejected, and the adequacy of documentation submitted by the assessee was upheld. The appeal was allowed, and the transfer pricing adjustment for the MSF was deleted.</description>
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