Expenses not charged to P&L cannot be adjusted to income in TP adjustment

Brief of the case: ITAT Hyderabad held in M/s DQ Entertainment (International) Ltd Vs ACIT that if the effect of expenses has been given in the balance sheet then the upward TP adjustment could not be made because the same had not been charged to P&L account and so same could not be be added to the income of the assessee. It further held that , if the assessee had paid management fees to its Associated Enterprise who had in turn paid fees to its Associated Enterprise then the same could not be denied on the basis that the ultimate services had not been rendered by the Associated Enterprise...