ITAT Upholds Deletion of Transfer Pricing Adjustment on Management Fees Under Rule 10AB Due to Lack of Evidence

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....The ITAT upheld the CIT(A)'s order deleting the transfer pricing adjustment made by the TPO on management fees paid by the assessee to its AE, rejecting the TPO's arbitrary adoption of the "other method" under Rule 10AB without adducing any comparable uncontrolled transactions. The Tribunal found that the TPO failed to comply with procedural mandates requiring substantiation of the ALP determination, and merely negated the assessee's application of TNMM without evidentiary support. The assessee convincingly demonstrated receipt and benefit of the intra-group services through comprehensive documentary evidence. The Tribunal also rejected the Revenue's contention regarding non-receipt of services and the characterization of the services as ro.........