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    <title>2023 (7) TMI 1082 - ITAT CHENNAI</title>
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    <description>On TP adjustment for management fees paid to AEs, the Tribunal held that the documentary evidence, including email correspondence, required fresh factual verification by the AO/TPO to determine ALP; the matter was remitted to the AO/TPO and the Revenue&#039;s ground was allowed for statistical purposes. On deduction under s.80-IA for operation of container freight stations, the Tribunal followed binding HC precedent treating a notified CFS as an eligible infrastructure facility; the Revenue&#039;s disallowance was rejected. On business development expenses incurred for client-staff tickets, the Tribunal accepted them as incurred for maintaining business relations; the disallowance was deleted. On employees&#039; PF/ESI contributions paid beyond statutory due dates, SC law was applied to deny deduction; the Revenue&#039;s ground was allowed.</description>
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      <description>On TP adjustment for management fees paid to AEs, the Tribunal held that the documentary evidence, including email correspondence, required fresh factual verification by the AO/TPO to determine ALP; the matter was remitted to the AO/TPO and the Revenue&#039;s ground was allowed for statistical purposes. On deduction under s.80-IA for operation of container freight stations, the Tribunal followed binding HC precedent treating a notified CFS as an eligible infrastructure facility; the Revenue&#039;s disallowance was rejected. On business development expenses incurred for client-staff tickets, the Tribunal accepted them as incurred for maintaining business relations; the disallowance was deleted. On employees&#039; PF/ESI contributions paid beyond statutory due dates, SC law was applied to deny deduction; the Revenue&#039;s ground was allowed.</description>
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