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Assessee Must Prove Services from Associated Enterprise for Management Fee Claims; Authorities to Evaluate Evidence Provided.

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....When the assessee claims that the assessee has paid the management fee to the AE, no doubt the burden is on the assessee to prove that it has received services from its AE. But when the assessee has produced such material before any of the authorities below it is also the duty of the authorities to consider the same before coming to any conclusion on merits. - AT....