https://www.taxtmi.com/caselaws?id=450253 The ITAT Delhi rejected the assessee's appeal regarding management fees paid to associated enterprises, ruling that each assessment year must be evaluated independently despite favorable decisions in prior years. The Tribunal found the assessee failed to prove actual receipt of services with convincing evidence, upholding the Transfer Pricing Officer's determination of arm's length price as nil. However, the ITAT allowed the assessee's appeal on interest on outstanding receivables from associated enterprises, following precedent that not all receivables from foreign associated enterprises constitute international transactions requiring case-by-case analysis of delay factors and working capital impact. en-us Wed, 28 Feb 2024 00:00:00 +0530 Fri, 01 Mar 2024 07:32:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450253 The ITAT Delhi rejected the assessee's appeal regarding management fees paid to associated enterprises, ruling that each assessment year must be evaluated independently despite favorable decisions in prior years. The Tribunal found the assessee failed to prove actual receipt of services with convincing evidence, upholding the Transfer Pricing Officer's determination of arm's length price as nil. However, the ITAT allowed the assessee's appeal on interest on outstanding receivables from associated enterprises, following precedent that not all receivables from foreign associated enterprises constitute international transactions requiring case-by-case analysis of delay factors and working capital impact. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450253