TPO's Use of CUP Method Over TNMM for Management Fee Rejected; TNMM Found Properly Applied in Transfer Pricing Case.

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....TP Adjustment - payment of management fee - In the absence of prerequisites for application of CUP method, it was not open for the ld. TPO to disregard TNMM employed by the assessee as MAM. No defects have been pointed out in application or relevance of TNMM in this case. Under these circumstances, impugned action of ld. TPO does not meet our judicial approval. - AT....