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9. The Ld.AR submitted that, Ground No.4 raised is not pressed by the assessee.

Accordingly, ground no.4 stands dismissed.

10. Ground No.5-10 relate to the assessee's challenge to the transfer pricing adjustment by which the TPO determined the ALP of the management service fees paid to its AE for intra-group services at Nil.

10.1 The Ld.AR submitted that the Ld.TPO failed to consider the benchmarking analysis undertaken by the assessee in its TPSR and proceeded to make an ad hoc adjustment by disallowing the entire intra-group service fee, solely by determining the ALP as Nil. It was contended that the Indian transfer pricing regulations prescribe a systematic and mandatory procedure for selection of the Most Appropriate Method ("MAM"). In this regard, reference was drawn to Section 92C(1) and 92C(2) of the Act, which provide that the ALP in relation to an international transaction shall be determined by applying one of the prescribed methods being; CUP, RPM, Cost Plus, Profit Split, TNMM, or any other method as notified--having regard to the nature of the transaction, the class of parties, functions performed, and other relevant factors. Sub-