TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges...

TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively fulfill (1) need test, (2) rendition test, (3) benefit test, (4) duplicative test and (5) shareholders activity test. On looking at the services it is apparent that some of the services have overlapped these tests. It cannot be said that even the IT network services should have a nil arm's-length price. - AO/TPO is directed to verify the claim of the assessee - AT .....

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