Tribunal held that assessee failed to provide organizational tree of the parent company vis-à-vis subsidiary and how the consultancy and other services are being rendered to the subsidiary by the holding company.  Complete facts have not been brought on record either by the assessee or any investigation have been made by the Revenue.  Assessee is harping upon TP study report prepared by its tax consultant and submitted that such charges are being calculated at arm’s length, which have not been doubted by the AO.  Therefore, Tribunal set aside orders of CIT(A) and remitted the matter to AO for adjudicating afresh directing AO to examine organizational structure of the holding company vis-à-vis the Assessee Company and to adjudicate that whether nexus was available between payment and services rendered.  (AY.  2009-10, 2011-12, 2012-13)