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2024 (1) TMI 68 - DELHI HIGH COURTDisallowance of management fees paid to ATS as being ‘excessive’ and ‘unreasonable’ - management fees paid by the respondent/assessee to ATS should have been added back to the income of assessee - HELD THAT:- We are of the view that the onus laid on the respondent/assessee was indeed discharged. We have also queried revenue as to whether the AO found fault with the documents furnished by the respondent/assessee in support of the plea that ATS did furnish services to the respondent/assessee, but he was not able to answer this question. Notwithstanding the above, there is no doubt that, given the material placed on record, the onus cast on the respondent/assessee was, in fact, discharged. Thus no substantial question of law arises for our consideration.
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