Transfer Pricing Adjustment Unjustified When Service Costs Are Well-Documented and Allocated Properly Among Group Companies.

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....TP adjustment - payment of shared service charges paid by the assessee to the AEs - once availing of various services from the AEs is duly substantiated by the documentary evidence and the cost allocation among the group companies is also on the basis of a well-accepted allocation key method, there is no basis in upholding the transfer pricing adjustment made by the TPO/AO. - AT....