Transfer Pricing Adjustment Made for Software Charges to Associated Enterprise; Third-Party Audit and Invoices Provided.

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....TP adjustment against payment to AE for Software charges - The charges have been paid pursuant to the agreement and the assessee has already placed on record third part audit certificate along with sample third party invoices raised by the vendors on its AE. In support of benefits, the assessee submitted a flowchart of the manufacturing operations, depicting the inter-linkage between the manufacturing operation and application provided /services received as part of IS and S3 services. - AT....