Transfer Pricing Ruling: Authorities Cannot Challenge Taxpayer's Decision on Management Services; Benefit Test Documentation Not Required.

TP adjustment - ALP of management service fees at Nil - receipt of service from other group companies not doubted - The authorities below cannot sit in judgment over the decision of assessee in availing the services and there is no question of providing documentation to specify the benefit test - Only thing which needs to be considered is whether the services have been provided - no disallowance .....

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