https://www.taxtmi.com/caselaws?id=432271 The Tribunal allowed the appeal, invalidating the TP adjustment orders due to procedural non-compliance and time-barred issuance. It also deleted the disallowance under Section 40(a)(i) for non-deduction of tax at source on management fees, as the payments did not qualify as Fees for Technical Services under the DTAA. en-us Wed, 09 Nov 2022 00:00:00 +0530 Mon, 10 Jun 2024 17:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432271 The Tribunal allowed the appeal, invalidating the TP adjustment orders due to procedural non-compliance and time-barred issuance. It also deleted the disallowance under Section 40(a)(i) for non-deduction of tax at source on management fees, as the payments did not qualify as Fees for Technical Services under the DTAA. Case-Laws Income Tax Wed, 09 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432271