It was noted that in the order passed by the Tribunal in the assessee’s own case for the immediately preceding assessment year, it was shown that in the identical fact situation, the Tribunal has held the transaction of Payment of management services fee at ALP. Thus, for lack of any distinguishing feature in the facts of the relevant AY, the precedent was followed and it was held that the international transaction of Payment of management services fees was at ALP. (AY. 2012-13)