Addition set aside as TPO erred in applying CUP method to fix ALP of management fee at 'nil'

IT/ILT : Where assessee-company engaged in manufacturing and marketing of speciality chemicals and printed circuit board, entered into cost sharing agreement with AE located abroad in terms of which certain group management cost was paid, in absence of proper examination of material brought on record in support of assessee's claim, TPO merely referring to CUP method could not determine ALP of management fee at nil