The learned CIT(A) has erred on facts and in law in deleting addition of Rs. 3,52,71,454 made on account of TP adjustment as : (a) The learned CIT(A) has erred in law in accepting the assessee’s contention that it is only intermediary between third party and AE. (b) The soul of the market support services functions is present in India as the assessee-company is responsible for discharging such functions as an independent organization and a lot of effect is required to be put into by it providing business promotion and research services and, therefore, it needs to be adequately compensated for such efforts. Therefore, such cost cannot be ignored and excluded for the purpose of computation of ALP of market support services fee.