https://www.taxtmi.com/highlights?id=66260 TP adjustment - ITAT decided that the transaction pertaining to receipt of administrative services to comparable uncontrolled price (‘CUP’) method - all the three authorities below have given concurrent findings of fact that the Appellant had failed to furnish evidence to demonstrate that administrative services were actually rendered by the AE and the assessee had received such services - Decided against the assessee - HC en-us Sun, 30 Oct 2022 21:20:02 +0530 Sun, 30 Oct 2022 21:20:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=66260 TP adjustment - ITAT decided that the transaction pertaining to receipt of administrative services to comparable uncontrolled price (‘CUP’) method - all the three authorities below have given concurrent findings of fact that the Appellant had failed to furnish evidence to demonstrate that administrative services were actually rendered by the AE and the assessee had received such services - Decided against the assessee - HC Highlights Income Tax Sun, 30 Oct 2022 21:20:02 +0530 https://www.taxtmi.com/highlights?id=66260