2015 (9) TMI 426

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....o. 6922/Mum/2007 - -<br>Income Tax<br>SHRI N.K. BILLAIYA AND SHRI VIVEK VARMA, JJ. For the Appellant : : S/Shri J D Mistri & K K Ved For the Respondent : Shri Vijay Kumar Bora ORDER PER VIVEK VARMA, JM: The instant miscellaneous applications (MAs) have been filed by the assessee to seek rectification of the order, concerning missing words, which were inadvertently left out and, whic....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....gement fee cannot be reduced from the addition made by the AO. I hasten to add that the amount mentioned in the grounds of appeal at Rs. 79,20,240/- includes management fee for work done for the Hongkong company as well as for the US company". 3. The AR submitted that as per the order of CIT(A), the issue of management fee was applicable for SJMH as well as SJMI. 4. Based on this undisputed ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... TP report submitted, wherein it was categorically mentioned that transaction involved the receipt of management fee from AE during the year ended 31.03.2002. The AR pointed out that the assessee had declared the same in the TP report in identification of revenues, which showed that 79,20,240/- pertained to SJMH and SJMI. It was also pointed out that it was declared and the same was accepted by th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... SJMI & SJMH. It is evident from the accounts submitted before the AO, because in the Profit & Loss Account submitted, it showed the receipt of Rs. 9,60,57,310/- which included Rs. 79,20,240/- under the head management fee for marketing support at Rs. 79,20,240/- (APB 7 & 12)". 8. Para 44 of the order would read as: "44. We, therefore, are of the opinion, that all the requisite details were ....