https://www.taxtmi.com/caselaws?id=464664 ITAT held in favor of the assessee, finding the TPO's determination of the arm's-length price for management services at NIL unsustainable due to contradictions and failure to identify defects in emails, invoices and service agreements evidencing receipt and costing. The tribunal followed the precedential approach of ITAT Mumbai and concluded the TPO did not justify treating the services as mere shareholder activity nor explain the "other method" used. The DRP's reliance on s.37 to disallow the fee was also found erroneous, and Ground No.6 was noted as not arising from the assessment order. en-us Wed, 09 Apr 2025 00:00:00 +0530 Sat, 08 Nov 2025 14:03:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464664 ITAT held in favor of the assessee, finding the TPO's determination of the arm's-length price for management services at NIL unsustainable due to contradictions and failure to identify defects in emails, invoices and service agreements evidencing receipt and costing. The tribunal followed the precedential approach of ITAT Mumbai and concluded the TPO did not justify treating the services as mere shareholder activity nor explain the "other method" used. The DRP's reliance on s.37 to disallow the fee was also found erroneous, and Ground No.6 was noted as not arising from the assessment order. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464664