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DRP Overlooks Evidence on Intra-Group Services; TPO's Arm's Length Price Adjustment to Nil Deemed Unsustainable.
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....TP Adjustment - intra/group services in the nature of management services - DRP ignored the evidences filed by the assessee demonstrating receipt of management services by merely stating that the assessee failed the benefit test. - Adjustment made by the TPO by determining the arm’s length price of the management services at nil is unsustainable. - AT....