TPO and DRP Misclassify ANPAP Services; Payments Deemed Arm's Length, No Extra Charges for Assessee. 'sLength.

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....TPA - the TPO and the DRP were in error in holding that the nature of services rendered by ANPAP were in the nature of stewardship activity or shareholder activity - The charges paid by the Assessee to ANPAP are held to be at Arm’s Length - no additions - AT....