Transfer Pricing Adjustment: Arm's Length Price Set to Nil Due to Lack of Evidence for Services Rendered.

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....TP Adjustment - reimbursement of expenses - Determining the arms length price as NIL - the assessee has not been able to prove the actual rendering of services/expenditure in respect of the assessee’s business by its oversees associated enterprise - the TPO was justified in determining the arms length price at “nil” - AT....