ALP of management fees paid to AE couldn't be held as nil if assessee was benefitted by substantial cost reduction

TRANSFER PRICING : Where TPO determined ALP of management fee paid by assessee to its AE at nil, in view of fact that assessee received services from AE for carrying out day-to-day managerial functions in course of its normal business activities and, moreover, assessee was benefitted by substantial cost reduction on an overall basis by utilizing services rendered by its AE, impugned order passed by TPO was to be set aside

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