Assessee Fails to Prove Arm's Length Price for Intra-Group Services; Case Remanded for Further Evidence on Key Tests.

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....TP Adjustment - intra group services - The assessee has failed to completely demonstrate the Arm’s Length Price of intra group services by satisfying need test, benefit test, rendition test, duplicative test etc . We set aside the whole issue back to the file of AO/ TPO with a direction to the assessee to substantiate the Arm’s Length Price of the intra group services demonstrating the above tests / ingredients mentioned. - AT....