ALP of services received from AE couldn't be taken as 'Nil' if assessee was deriving benefit from such services

TRANSFER PRICING : Where in case of assessee, TPO determined ALP of management fee paid to AE at nil on ground that such services were in nature of 'stewardship activity' in view of fact that services rendered by AE under various segments such as 'Business Development', 'Supply Chain Management' and 'Distribution sales services', were in nature of normal business services performed with a view to enable assessee to carry out its business operations efficiently, said services did not qualify as '

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