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2012 (9) TMI 67 - AT - Income TaxTransfer pricing adjustment - adjustment on account of payments of Management Fees, selling commission and reimbursement of expenses - Held that:- Considering submission of several documents to substantiate the actual rendition of services for which payment of management fee and sales commission was made by the Appellant Company to its associated enterprise depicts that the Appellant Company has actually received services from its associated enterprise for which management fee has been paid. Further, these documents also substantiate that the services received by the Appellant Company from its associated enterprise are substantial in nature. As the additional grounds of appeal filed by the assessee are admitted for adjudication and all these issues require thorough examination and verification of data filed and likely to be called for the additional evidence and connected issues be restored back to the file of the Assessing Officer for de novo consideration - in favour of assessee for statistical purposes.
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