TPO Cannot Value Management Fees at Nil Without Rejecting Evidence of Services Rendered

Gates India Private Limited Vs Assessment Unit (ITAT Delhi) The ITAT Delhi considered the assessee’s appeal against the assessment order passed under Sections 143(3), 144C(13) and 144B of the Income-tax Act for Assessment Year 2020-21, arising from the directions of the Dispute Resolution Panel (DRP). The appeal challenged multiple transfer pricing (TP) adjustments relating to management charges, royalty payments, interest on outstanding receivables, and employees’ contribution to PF and ESI. The assessee, engaged in the manufacturing, trading and marketing of rubber hoses and hose...