PCIT v. Nippon Leakless Talbros Pvt. Ltd. (2023)455 ITR 335/ 153 taxmann.com 279 (P&H)(HC)

S. 40A(2) : Expenses or payments not deductible-Excessive or unreasonable-Management fees-International Transactions-Transfer Pricing-Res Judicata-Commercial expediency-Principles of consistency and rule of finality applied. [S. 40A(2)(b), 92A(3), 144C, 260A]

Dismissing the appeal of the Revenue  the Court held that  the principle of consistency and rule of finality applied. The Tribunal was right in allowing the management fees paid to its associated enterprises.(AY.2010-11)