Dismissing the appeal of the revenue the Court held that the Tribunal took into consideration the voluminous documentary evidence on record in the form of e-mail correspondence indicating the rendition of services. The Tribunal was right in its view that the assessee would be the right person to know whether or not the services were required. Such issues should be left best to the commercial wisdom of the assessee. What was important was whether or not the services were rendered and whether the cost allocation was on a fair and reasonable basis. The rendition of services had not been disputed. However, a great deal of emphasis had been put on the issue of arm’s length price in respect of the management fees. This aspect had also been well discussed by the Tribunal. The decision of the Tribunal was correct and required no interference.(R/TA No. 106 of 2019 dt 27 -08 -2019 )  (AY. 2010 -11)