ITAT Deletes Management Fee TP Adjustment as Issue Was Already Decided in Earlier Years

NTT India Private Limited Vs DCIT (ITAT Mumbai) The appeal concerned Assessment Year 2020-21 and challenged various additions made in the assessment order passed under Sections 144C(13) and 144B pursuant to directions issued by the Dispute Resolution Panel (DRP). The principal dispute related to transfer pricing adjustments on account of management fees paid to an associated enterprise (AE). The assessee was engaged in trading networking products and providing related services including training, maintenance, installation, consultancy, facility management, outsourcing, and systems integration ...