https://www.taxtmi.com/caselaws?id=311874 ITAT Delhi upheld disallowance of group management fee paid to associate enterprises under section 37(1). The assessee advertising agency failed to produce cogent evidence demonstrating the expenditure was incurred wholly and exclusively for business purposes. Despite being covered by transfer pricing provisions, the assessee could not substantiate actual occurrence of management services across ten claimed service heads. The tribunal relied on Cushman and Wakefield precedent, confirming that transfer pricing coverage does not bypass AO's function under section 37(1) to determine business expenditure validity. en-us Thu, 30 Jun 2022 00:00:00 +0530 Thu, 18 Jan 2024 18:18:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311874 ITAT Delhi upheld disallowance of group management fee paid to associate enterprises under section 37(1). The assessee advertising agency failed to produce cogent evidence demonstrating the expenditure was incurred wholly and exclusively for business purposes. Despite being covered by transfer pricing provisions, the assessee could not substantiate actual occurrence of management services across ten claimed service heads. The tribunal relied on Cushman and Wakefield precedent, confirming that transfer pricing coverage does not bypass AO's function under section 37(1) to determine business expenditure validity. Case-Laws Income Tax Thu, 30 Jun 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311874