ITAT Rules Against Assessee: Insufficient Evidence on Transfer Pricing Adjustment for Administrative Services Using CUP Method.

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....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....