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ALP of management services unit charges paid to AE not to be taken as nil if services weren't duplicitous in nature

January 31, 2019[2019] 101 360 (Delhi - Trib.)

IT/ILT: Where TPO determined ALP of amount paid by assessee as management services unit charges to its AE at nil on ground that those services were duplicative in nature, in view of fact that payment of said charges was distinct and, huge sales volume could not be achieved by assessee without aid of support staff provided by AE, impugned order passed by TPO was to be set aside

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