Transfer Pricing Dispute: Assessee Fails to Provide Detailed Breakdown of Management Fees; TPO Rejects Lump Sum Explanation.

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....TP Adjustment on account of the Management fees and payment of R&D expenses - As regards, failure of the Assessee to provide service wise break-up of management fee, the Assessee had explained that the Assessee was being charged a lump sum fee for the management services and therefore, was not able to furnish the service-wise break up.TPO failed to take the same into consideration. - AT....