TPO's Transfer Pricing Adjustment Overturned for Incorrectly Valuing Regional Management Services; Section 92C Methods Ignored.

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....TP Adjustment - regional management services received by the assessee - incorrect factual observations and invalid of assumption of jurisdiction by the TPO who without following any of the methods provided in Sec.92C had determined the arm‟s length price of the transaction of receipt of regional management services by the assessee from its domestic AE at Nil - pricing adjustment made by the TPO vacated - AT....