ITAT sets aside TP adjustment when TPO had proceeded on wrong facts to determine nature of services

IT/ILT : Where in transfer pricing proceedings, TPO taking value of management fee paid to AE at nil, made certain addition to assessee's ALP, in view of fact that in support of services rendered, assesee had brought on record invoices raised by AE and, moreover, TPO had proceeded on wrong facts regarding nature of services rendered, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh