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“management fees”

Transfer PricingSection 92BSection 92B344 judgments

REGUS SOUTH MUMBAI BUSINESS CENTRE PVT. LTD.,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - 14(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 6104/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Mar 2026AY 2012-13

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarregus South Mumbai Dcit - 14(1)(2), Business Centre Mumbai Private Limited, Vs. Aayakar Bhavan, M. Level 4, Dynasty K. Road, New Marine Business Park, Andheri Lines. Mumbai- Kurla Road, J. B. Nagar 400 020 S.O, Mumbai – 400 059 Pan/Gir No. Aadcr6068H (Applicant) (Respondent) Assessee By Shri Ketan Ved, Ld. Ar Revenue By Smt. Usha Gaikwad, Ld. Dr Date Of Hearing 16.03.2026 Date Of Pronouncement 26.03.2026

Section 143(3)

Accordingly, the Assessing Officer disallowed the entire amount of Rs. 21,06,749/-. 5. The Assessing Officer further observed that the assessee had debited management fees amounting to Rs. 21,78,430/- which included prior period expenses of Rs. 1,70,952/-. Since no satisfactory explanation was furnished for such

AURA SECURITIES PRIVATE LIMITED,AHMEDABAD vs. NFAC, DELHI PRESENT JURISDICTION THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 1725/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad12 Feb 2026AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2018-19

Section 143(3)Section 14ASection 36

assessee explained that the assessee had suo moto made disallowance of Rs. 3,12,761/- u/s 14A of the Act, in respect of management fees, carpediem fund operating expense and demat charges. Further interest paid in respect of borrowed fund to the extent of Rs. 40,73,658/- was also

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD., KASTURBA NAGAR

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21
For Appellant: \nShri Ashwani Taneja, AdvocateFor Respondent: \nMs. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

A.Ys.2001-02 to 2003-04 in the case of M/s.\nPower Finance Corporation Ltd and held that the income from upfront\nfees, management fees and agency fees are not income derived from\nbusiness of long-term finance and the same cannot be treated as profits\neligible for deduction

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2289/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Feb 2026AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

corpus. The ld. AR further submitted that no complaints are received from the parents or students regarding charging of development fees and collection of management fees for incurring capital expenditure is allowed by UGC notification dated October 1997 as per the prescribed guidelines. 38. The ld DR argued that

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2251/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

corpus. The ld. AR further submitted that no complaints are received from the parents or students regarding charging of development fees and collection of management fees for incurring capital expenditure is allowed by UGC notification dated October 1997 as per the prescribed guidelines. 38. The ld DR argued that

ARCIL SBPS 001 I TRUST ,MUMBAI vs. DCIT(TDS)-1(1), MUMBAI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 4700/MUM/2025[2017-18]Status: DisposedITAT Mumbai04 Feb 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokararcil Sbps 001 I Trust Dcit (Tds)-(1)(1), The Ruby, 10Th Floor, 29, Mtnl Building, Senapati Bapat Marg, Vs. Cumballa Hills, Dadar (W), Mumbai- Pedder Road, 400 028 Mumbai-400 026 Pan/Gir No. Aabta3859J (Applicant) (Respondent) Assessee By Shri Rahul Sarda, Ld. Ar Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 04.02.2026

Section 115TSection 133Section 194LSection 201Section 201(1)Section 250

utilises the same for acquisition of financial assets. The financial assets are realised over a period and the surplus, after adjusting expenses and management fees, is distributable to the Security Receipt holders in accordance with the trust deed and regulatory framework. 3. A survey under section

OSG (INDIA) PRIVATE LIMITED,GURGAON vs. DCIT, CIRCLE-3(1), GURGAON

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4925/DEL/2024[2021-22]Status: DisposedITAT Delhi04 Feb 2026AY 2021-22

Bench: Shri Yogesh Kumar Us & Shri Brajesh Kumar Singh

Section 143(3)Section 144B

consumable 16212781 TNMM and raw materials 2. Import of finished 189157950 goods 3. Export of manufactured 9697933 goods 4. Commission Income 6838613 5. Management Fees 2789936 6. Import of machineries 21953 Other method 7. Foreign technician 1392828 expenses / job work/ others 8. Reimbursement of 8244887 expenses 3.3 The TPO noted ... that the assessee had paid a sum of Rs. 27,89, 936/- to its AE on account of ‘Management fees’. The TPO noted that as per OECD guidelines primarily the assessee had failed to substantiate that any services have been rendered by the AE for which management fee was paid

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18
Section 143(3)Section 43(1)

lower authorities and direct the\nLd.AO to delete the impugned addition of Rs.5,08,36,826/- on account of\ndownward adjustment of payment of management fees towards global account\nmanagement charges. All the grounds of appeal raised by the assessee on\nthis issue are therefore allowed.\"\n43. The Ld.AR placed

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15
Section 143(3)Section 43(1)

lower authorities and direct the\nLd.AO to delete the impugned addition of Rs.5,08,36,826/- on account of\ndownward adjustment of payment of management fees towards global account\nmanagement charges. All the grounds of appeal raised by the assessee on\nthis issue are therefore allowed.\"\n43.\nThe Ld.AR placed

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16
Section 143(3)Section 43(1)

lower authorities and direct the\nLd.AO to delete the impugned addition of Rs.5,08,36,826/- on account of\ndownward adjustment of payment of management fees towards global account\nmanagement charges. All the grounds of appeal raised by the assessee on\nthis issue are therefore allowed.\"\n43. The Ld.AR placed

DCIT (TDS)-2(3), MUMBAI, MUMBAI vs. TATA PLAY LIMITED, MUMBAI

In the result, the appeal of revenue stands dismissed, in terms of aforesaid\nappeals

ITA 5623/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Jan 2026AY 2016-17
Section 194CSection 194HSection 194JSection 201Section 201(1)

treating the assessee as an 'assessee-in-\ndefault' u/s 201(1) for short deduction of TDs in respect of payments made\ntowards 3 document management fees' without appreciating the fact that the\nnature of services received by the assessee requires certain parameters of\ntechnical/managerial skill of highly qualified specialized competency ... sale\nof Tata Sky Starter Kits & Recharge Coupons, issue of TDS on payments made\nfor installation service provider and on the issue of document management fee as\nthese short deductions have been deleted by him without appreciating that the\nsame are also the subject matter of further appeal, as mentioned

CENTRE FOR E-GOVERNANCE ,BANGALORE vs. DCIT, EXEMPTION, CIRCLE-1 , BANGALORE

ITA 936/BANG/2025[2021-22]Status: DisposedITAT Bangalore31 Dec 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri S Parthasarthi, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 11Section 11(1)(a)Section 12ASection 2(15)

significant receipts from private institutions in the form of tender processing fees, e-auction fees, supplier registration fees, renewal fees, catalogue PO fees, contract management fees, security fees and transaction fees. The AO also noted that the assessee earned a very high amount of interest income ... fees . Page 12 of 30 ii. E-auction Fee iii. Supplier registration fees iv. Supplier registration renewal fee v. Catalogue PO fees vi. Contract Management fees vii. Security fee from private institution and viii. Transaction fee from private institutions Whereas the expenditure side largely include charges such as 1. salaries

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2917/DEL/2024[2018-19]Status: DisposedITAT Delhi31 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

term deposits. 2(b) Interest on staff loans. 2(c) Incomes under the head business service charges which includes following: Business ServiceCharges Refund of management fees Rs.78,26,350/- Lead institution fees Rs. 85,453/- Fees based activity Rs.25,10,326/- Miscellaneous Income- others Rs.1,20,26,745/- Interest rate ... business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fees Rs.85,453 (c) Fees based activity Rs.25,10,326 (d) Interest rate swap income Rs.2

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2916/DEL/2024[2017-18]Status: DisposedITAT Delhi31 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

term deposits. 2(b) Interest on staff loans. 2(c) Incomes under the head business service charges which includes following: Business ServiceCharges Refund of management fees Rs.78,26,350/- Lead institution fees Rs. 85,453/- Fees based activity Rs.25,10,326/- Miscellaneous Income- others Rs.1,20,26,745/- Interest rate ... business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fees Rs.85,453 (c) Fees based activity Rs.25,10,326 (d) Interest rate swap income Rs.2

DCIT, CIRCLE-10(1), DELHI vs. INDIAN RENEWABLE ENERGY DEVELOPMENT AGENCY LIMITED, DELHI

ITA 2915/DEL/2024[2016-17]Status: DisposedITAT Delhi31 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)

term deposits. 2(b) Interest on staff loans. 2(c) Incomes under the head business service charges which includes following: Business ServiceCharges Refund of management fees Rs.78,26,350/- Lead institution fees Rs. 85,453/- Fees based activity Rs.25,10,326/- Miscellaneous Income- others Rs.1,20,26,745/- Interest rate ... business service charges, we find that in AY: 2010-11 this head involves the following: Sr. No. Details of Income Amount (a) Refund of management fees R.78,26,350 (b) Lead institution fees Rs.85,453 (c) Fees based activity Rs.25,10,326 (d) Interest rate swap income Rs.2

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