Parent Firm Must Charge for Support Services; 5% Markup Deemed Fair for Transfer Pricing Adjustment 'sLength.

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....TP Adjustment - ALP adjustment on account of profit mark-up - It cannot be expected that the parent organization supply support services without charging anything for such services rendered. Hence, we hold that the markup of 5% is sufficient to recoup the expenditure involved by the AE in exploration, inspection, testing and finalization of the suitable software. - AT....