Tribunal held that, TPO accepted that services were rendered by AEs for which management fee had been paid, hence he was not correct in holding that arm’s length value of management fee was nil and accordingly making an upward adjustment. (AY. 2009 -10)
CEVA Freight India (P.) Ltd. v. DCIT (2019) 176 ITD 341 (Delhi) (Trib.)
S. 92C : Transfer pricing-Arm’s length price-Management fee-TPO is not justified in holding that arm’s length value of management fee was nil and accordingly making an upward adjustment.