TMI Blog2015 (9) TMI 426X X X X Extracts X X X X X X X X Extracts X X X X ..... a Branch from SJMH related to services provided to both SJMI & SJMH. It is evident from the accounts submitted before the AO, because in the Profit & Loss Account submitted, it showed the receipt of ₹ 9,60,57,310/- which included ₹ 79,20,240/- under the head management fee for marketing support at ₹ 79,20,240/-. Para 44 of the order read as: - “44. We, therefore, are of the opinion, that all the requisite details were placed before the AO, along with the return on income, which based the computation of returned income on receipts related to services provided to both SJMH and SJMI Since the absence of the missing words would affect the basic structure of the order, wherein, we had deleted the addition of ₹ 1,76 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cannot be reduced from the addition made by the AO. I hasten to add that the amount mentioned in the grounds of appeal at ₹ 79,20,240/- includes management fee for work done for the Hongkong company as well as for the US company . 3. The AR submitted that as per the order of CIT(A), the issue of management fee was applicable for SJMH as well as SJMI. 4. Based on this undisputed finding of the CIT(A), which was sustained, Para 36 of the order would read as: 36. The assessee approached the CIT(A), before whom it was submitted that the claim of ₹ 79,20,240/- as management fee was attributable to SJMH and SJMI. The CIT(A), after taking into consideration the accounts of the assessee, concluded that management fee received ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alt with extensively and in the process, the TPO found the receipt of management fee by the India Branch from SJMH related to services provided to both SJMI SJMH. It is evident from the accounts submitted before the AO, because in the Profit Loss Account submitted, it showed the receipt of ₹ 9,60,57,310/- which included ₹ 79,20,240/- under the head management fee for marketing support at ₹ 79,20,240/- (APB 7 12) . 8. Para 44 of the order would read as: 44. We, therefore, are of the opinion, that all the requisite details were placed before the AO, along with the return on income, which based the computation of returned income on receipts related to services provided to both SJMH and SJMI . 9. Since the abse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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