TPO's 'NIL' ALP Decision on WeWork Management Fee Unjustified; Assessee Relies on WeWork's Expertise for India Operations.

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....TP adjustment in respect of management fee - When the TPO alleges that the assessee has not received any of the above services, it would indicate that the very relationship based on which the assessee company and WeWork Global have been established as AE would be nonexistent. - it is beyond doubt that the assessee is wholly dependent on the use of know-how, patents, copyright, trademark, licences, franchise and other services of We Work Global, for its day to day operation in India. - TPO is not justified in treating the ALP of management fee paid by assessee to WeWork Global at ‘NIL’. - AT....