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“management fees”

Transfer PricingSection 92BSection 92B344 judgments

The decision most relied on for management fees is J.K. (Bom.) Limited v. CBDT and Another (118 ITR 312), cited in 50 judgments on BharatTax.

Leading authorities on management fees

J.K. (Bom.) Limited v. CBDT and Another
118 ITR 312 · 1979 · High Court
50
citing judgments

The case elucidates the meaning of 'management services', detailing its components and considering whether such services qualify as 'technical services' for income tax purposes, particularly in relation to fees for technical services.

Commissioner of Income Tax v. Merck Ltd.
389 ITR 70 · 2016 · High Court
48
citing judgments

Ad-hoc transfer pricing adjustments are not justified if the Transfer Pricing Officer fails to apply one of the prescribed methods under Section 92C. The arm's length nature of international transactions, including intra-group services and management fees, should be determined through a detailed FAR analysis and benchmarking study.

DIT v. HCL Infosystems Ltd.
144 Taxmann 492 · 2005 · High Court
45
citing judgments

Reimbursement of salary costs of employees is not taxable as Fees for Technical Services (FTS) under the Act. Additionally, for a fixed place Permanent Establishment (PE) or place of management to exist, business premises must be made available or a right to use them must be established.

US Technology Resources (P) Ltd. v. CIT
97 Taxmann.com 642 · 2018 · High Court
34
citing judgments

Payments for advice on management, financial, or legal services, offered on a factual basis without transferring technical know-how, are not taxable in India as fees for technical services.

CIT v. Edward Keventer (P.) Ltd.
115 ITR 149 · 1978 · Supreme Court
28
citing judgments

When assessing expenses under Section 40A(2), tax authorities must consider the entire position judiciously from the viewpoint of a prudent businessman, not arbitrarily or capriciously. The revenue must demonstrate tax evasion and cannot disallow expenses if the recipient is taxed at the same or higher rate.

Gujarati Charitable Foundation Poona (2018) 402 ITR 441(SC) 4. CIT v. Sardarilal& Co.
266 CTR 181 · 2014 · Reported
22
citing judgments

The denial of exemption under Section 11 is justified if trustees manage the trust's finances as their personal business, collecting excess fees from students.

(v). Wockhardt Ltd. v. ACIT
10 Taxmann.com 208 · 2011 · Reported
20
citing judgments

Services rendered by employees of a non-resident company, which involve sharing management experiences and business strategies, are not considered technical services for the purpose of taxation as Fees for Technical Services (FTS).

Gemplus India (P) Ltd. v. ACIT
3 Taxmann.com 755 · 2010 · ITAT
20
citing judgments

The Assessing Officer (AO) may determine the Arm's Length Price (ALP) to be 'Nil' for intra-group services if the services were not actually rendered or if the payment is not commensurate with the benefits derived. This position aligns with the Gemplus India case where management fees were challenged.

Judgments citing management fees

Nsdc Skill Impact Trust, New Delhi vs. CIT(Exemption), Delhi

In the result, both the appeals of the assessee are allowed

ITA 2153/DEL/2025[2023-24 TO 2025-26]Status: DisposedITAT Delhi30 Jun 2025

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri K. V. S. R. Krishna, CAFor Respondent: Shri Jitender Singh, CIT DR
Section 12(1)(ac)Section 12ASection 12A(1)(ac)Section 80G

services to NSDC for consideration of payment of 10% on actual expenses as compensation. The assessee submitted before the ld CIT(E) that 10% management fee collected is only to recover the operation cost incurred by the assessee trust. It is not profit driven fee charges but only reimbursement ... assessee and concluded that the assessee has not engaged in the charitable activities but only engaged in rendering services of collection of management fees of 10%. Hence, he concluded that the activities carried out by the assessee are business/ target oriented and commercial in nature rather than charity-focused. Accordingly

Fugro Survey (India) Private Limited, Navi Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the grounds of appeal raised by

ITA 6042/MUM/2024[2021-22]Status: DisposedITAT Mumbai25 Jun 2025AY 2021-22

Bench: Shri Pawan Singh & Girish Agrawal(Physical Hearing) Fugro Survey (India) Private Limited, Dcit, Circle -15(1)(1), D-222/30, Furgo House, Ttc Vs Room No. 451, Aayakar Bhawan, Industrial Area, Darave B.O., Nerul, M.K. Road, Navi Mumbai-400706 Mumbai-400020 [Pan No. Aaacf 5343 R] Appellant / Assessee Respondent / Revenue

Section 143Section 143(3)Section 144BSection 144C(13)Section 254(1)Section 92D

transfer pricing adjustment of ₹ 3,27,07,848/- on the same. 4. Ground no. 4: with respect to the international connection of payment of management fees to its AEs the AO and the TPO and honourable DRP have erred in law and facts by concluding the said international transaction ... adjustment of ₹ 4,60,82,919 /-. 5. Ground No. 5: with respect to the international transaction of payment of our and the fee and management fees to its AEs, the AO, TPO and honourable DRP have erred in law and facts by concluding on a faulty assumption of service

Ntt India Private Limited, Mumbai vs. Asstt Comm. of Income Tax-14(1)(1), Mumbai

In the result, the appeal is accordingly partly allowed for statistical purposes

ITA 2491/MUM/2022[2018-19]Status: DisposedITAT Mumbai24 Jun 2025AY 2018-19

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanntt India Private Vs. Assessment Unit/Nfac/Dcit Limited Circle 15(1)(2), 1701-1704, B Wing, One Mumbai Bkc, Level 17, G-Block, Aayakar Bhavan, Plot No. C-65, Bandra Mumbai. Kurla Complex, Bandra East, Mumbai-400 051. Pan/Gir No. Aaacd2145G (Applicant) (Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 144CSection 271ASection 92C

clarified. Therefore, the AE is not required to be compensated under the head management services. xi) The claim of assessee that assessee's management fees agreement entails 10 kinds of services to be provided to assessee was rejected by the TPO on the ground that assessee has failed to show ... service category. 8. Thus the TPO has rejected the assessee's entity level benchmarking of the international transaction of cost contribution of management fees for two reasons:- (1) Firstly, the cost contribution constitutes a small part of the total transactions of the assessee company at the entity level. Therefore

Jackie Mahesh Vora, Mumbai vs. ACIT Circle 19(2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 6018/MUM/2024[2017-18]Status: DisposedITAT Mumbai20 Jun 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri K. Gopal/Shri Akhilesh Deshmukh, A/RsFor Respondent: Ms. Kavita P. Kaushik, Sr. D/R
Section 57

against which he claimed deduction of Rs. 1,32,88,293/- on account of payment of loan interest at Rs.1,32,14,955/- and management fees of Rs.73,338/- which resulted in a loss of Rs. 28,05,940/-. The AO asked the assessee to justify its claim of interest

Bostik India Private Limited, Bangalore vs. Dc/ACIT Circle(2)(1)(1), Dc/ACIT Circle

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 2472/BANG/2024[2021-2022]Status: DisposedITAT Bangalore16 Jun 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

For Appellant: Sri Sumeet Khurana, A.RFor Respondent: Dr. K.J. Dhivya, D.R
Section 234A

Commercial services (IT Support services) 2. License 52,58,825 54,21,169 56,40,000 Technology Renewal fee 3. Management Fees 4,22,69,056 3,01,67,905 2,67,01,782 Total 4,75,27,881 3,55,89,074 3,43,38,782 16.1 We shall ... first adjudicate the payments made for Technology License renewal fees and management fees. With respect to the above two payments to AE, the choice of method of benchmarking, the assessee has considered TNMM as MAM and the TPO has considered `hypothetical CUP’ by rejecting TNMM. The basis of rejection

DCIT-2 1 1 Mumbai, Mumbai vs. Iss Facility Services India Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is partly allowed for statistical

ITA 2208/MUM/2025[2014-15]Status: DisposedITAT Mumbai16 Jun 2025AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Nikhil TiwariFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 10(35)Section 143(3)Section 144C(3)Section 14ASection 153Section 250

year under consideration, the assessee entered into international transactions, inter alia, pertaining to the payment of Management Service Fees and payment of Global Client Management Fees with its AE, i.e., ISS World Services A/S, Denmark. As per the Transfer Pricing Study Report, under the international transaction pertaining to payment ... Management Service Fees received ITA No.2208/Mum/2025 & CO No.109/Mum/2025 (A.Y. 2014-15) 6 by the assessee to be ₹ `Nil'. However, as regards the Global Client Management Fees paid by the assessee, the TPO, after considering the documents furnished by the assessee, held that these documents/evidence do reveal that the central team

M/S. Castlewick Fze, Dubai vs. ACIT, International Taxation, Circle-1(1), Chennai

ITA 459/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Jun 2025AY 2018-19
For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 139Section 143(2)Section 143(3)Section 144C(1)Section 148Section 201Section 201(1)Section 234ASection 9(1)(vii)

आयकर अपीलीय अधिकरण, 'ए' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, CHENNAI श्री जॉर्ज जॉर्ज के, उपाध्यक्ष

Fena Private Limited, Delhi vs. Assessment Unit, NFAC, Income Tax Department, Delhi

In the result, both the appeals of the Assessee are partly allowed

ITA 2475/DEL/2024[2020-21]Status: DisposedITAT Delhi11 Jun 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(3)Section 14ASection 14A(3)

2475/Del/2024 Fena Pvt Ltd investments being handled by the fund manager on behalf of the Assessee was substantial, the fund manager was paid management fees / brokerage from the fund itself and that no expenditure was sought to be incurred by the Assessee to the fund manager. Further, it was submitted ... Assessee Company, it could be seen that there were no payments made to the fund manager either in the form of brokerage, management fee, or any form of remuneration, etc. However, this explanation was not accepted by the lower authorities and eventually, the disallowance under section

Fena Private Limited, New Delhi vs. Additional, Joint, Deputy, ACIT, ITO, National E-Assessment Centre, Delhi

In the result, both the appeals of the Assessee are partly allowed

ITA 2474/DEL/2024[2018-19]Status: DisposedITAT Delhi11 Jun 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Raj Kumar, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(3)Section 14ASection 14A(3)

2475/Del/2024 Fena Pvt Ltd investments being handled by the fund manager on behalf of the Assessee was substantial, the fund manager was paid management fees / brokerage from the fund itself and that no expenditure was sought to be incurred by the Assessee to the fund manager. Further, it was submitted ... Assessee Company, it could be seen that there were no payments made to the fund manager either in the form of brokerage, management fee, or any form of remuneration, etc. However, this explanation was not accepted by the lower authorities and eventually, the disallowance under section

Deputy Commissioner of Income Tax, Gurgaon vs. Hays Business Solutions Private Limited, Gurgaon

The appeal of the Revenue is dismissed

ITA 3003/DEL/2023[2014-15]Status: DisposedITAT Delhi29 May 2025AY 2014-15

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 143(2)Section 143(3)Section 195(1)Section 250Section 37Section 40

case, the CIT(A) has erred in deleting the addition of Rs.3,48,56,596/- made u/s 37, claimed an account of management fees when the assessee failed to submit documentary evidence in respect of such transactions? (ii) Whether on the facts and in the circumstances of the case ... erred in deleting the addition of Rs.3,48,56,596/- u/s 40(a)(ia) of the Act claimed on account of management fees, in absence of deduction of TDS ?” 3. In both the grounds of appeal, the Revenue has challenged the action of ld. CIT(A) in deleting the disallowance

Assistant Commissioner of Income Tax-16(1), Mumbai vs. Matrix Publicitiies and Media Pvt Ltd, Mumbai

In the result, appeal by the revenue is dismissed and cross objection by the assessee is allowed

ITA 5174/MUM/2024[2017-18]Status: DisposedITAT Mumbai28 May 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2017-18 Assistant Commissioner Vs Matrix Publicities & Of Income Tax-16(1), Media India Pvt. Ltd. Mumbai 7Th Floor Bay 99, The Orb, Sahar P & T Colony, S.O., Mumbai 400099 (Pan: Aadcm8510H) Appellant Respondent

For Appellant: Shri Nikhil Tiwari, CAFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr DR
Section 143(3)Section 40Section 69C

facts of the case and submissions made, thereby further contesting the various issues before the Hon’ble Tribunal by filing an appeal; Disallowance of management fees of Rs 6,67,05,092 2. erred in objecting to the order of Ld. CIT(A) that no TDS is deducted ... filed cross objection to defend the relief it got. i. Disallowance under Section 40(a)(i) and Section 69C of the Act towards management fees paid to Wunderman Pte Limited (‘Wunderman Pte’) amounting to Rs. 6,67,05,092 Matrix Publicities and Media Pvt. Ltd. A.Y. 2017-18 ii. Disallowance

Delicatessen Engineering Services Private Limited, Hyderabad vs. DCIT., Circle- 8(1), Hyderabad

In the result, appeal filed by the assessee is partly allowed

ITA 835/HYD/2024[2020-21]Status: DisposedITAT Hyderabad15 May 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita No.835/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2020-21) Delicatessen Vs. Dy. Cit. Engineering Services Circle- 8(1), Private Hyderabad Limited,Hyderabad Pan:Aagcd8678N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri B Bala Krishna, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 26/02/2025 घोषणा की तारीख/Pronouncement: 16/05/2025 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(13) R.W.S. 144B Of The I.T. Act, 1961 Dated,18/07/2024, In Pursuant To The Directions Issued By The Drp-1 Bengaluru, Dated 26/02/2024 U/S 144C(5) Of The I.T. Act, 1961 & Relating To A.Y.2020-21. Page 1 Of 32

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri B Bala Krishna, CIT(DR)
Section 143(3)Section 144C(5)Section 92C

also rejected the ground taken by the assessee challenging the reasons given by the TPO for not considering the amortization of goodwill and management fee and termination fee as part of operating cost on the ground that the amortization of goodwill is part of the operating cost of the assessee ... also management fee & termination fee is part of the cost of the assessee as is evident from the treatment given by the assessee in its books of account. Therefore, rejected the grounds of objections filed by the assessee. Page 9 of 32 ITA No 835 of 2024 Delicatessein Engg. Services

Toyota Boshoku Automotive India Private Limited, Bidadi vs. Assessment Unit, Income Tax Department Or the DCIT, Circle - 7(1)(1), Koramangala

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

ITA 1539/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore09 May 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Ms. Neera Malhotra, CIT (DR)
Section 234ASection 270A

assessee before us aggregated all the international transaction by using TNNM as the most appropriate method to benchmark the international transactions. The Ld.TPO segregated management fees and royalty payment, which constituted major part of the transaction. The entire dispute before us, is in respect of the method used for benchmarking

DCIT-2(1)(1), Mumbai vs. Iss Facility Services India Pvt. Ltd., Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1980/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 May 2025AY 2015-16

Bench: Shri Pawan Singh, Hon’Bleshri Girish Agrawal, Hon’Blec.O. No.97/Mum/2025 (By Assessee) (Physical Hearing) Dy Commissioner Of Income Tax, Iss Facility Services India Pvt Ltd, Ground Floor, East Wing, Circle -2(1)(1), Room No. 575, Leela Business Park, 5Th Floor, Aayakar Bhawan, Vs Near Airport Road, Metro Station, M.K. Road, Mumbai-400020, Andheri East, Mumbai. Pan. Aabci 3815 M Appellant (Respondent) Revenue Represented By : Shri S.S. Bhagat Sr Dr Assessee Represented By : Shri Nikhil Tiwari, Ca Date Of Hearing : 06.05.2025 Date Of Pronouncement Of Order : 06.05.2025 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh;

Section 143(3)Section 153Section 254(1)Section 92C(1)

referred above. The relevant extract of the decision is reproduced as under: “3.9 As regards the international transaction of Payment of Global Client Management Fee, it is also evident that TPO in subsequent assessment years has partially accepted the assessee's submission of rendition of service by AB and made ... 92C/1) of the Act was followed by TPO/ DRP for upholding partial adjustment in respect of international transaction pertaining to Payment of Global Client Management Fee and same was done merely on ad-hoc basis, TPO is directed to delete the transfer pricing adjustment

DCIT 3(2)(1), Mumbai vs. Jovial Investment and Trading Company Private Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 5025/MUM/2024[2017-18]Status: DisposedITAT Mumbai02 May 2025AY 2017-18

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Prashant Barate, Sr.DR
Section 147Section 148Section 14ASection 250Section 68Section 69C

Long Term Capital Loss 73,76,279 (73,76,279) Disallowed Short Term Capital Loss 6,88,164 (6,88,164) Disallowed Management Fees PMS 8,51,142 (8,51,142) Disallowed Brokerage 1,54,123 (1,54,123) Disallowed Provision for Sub-Standard Assets

DCIT Central Circle- 5(4), Mumbai vs. Shrem Infraventures Prt. Ltd., Mumbai

In the result, appeal of the revenue is dismissed

ITA 1561/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Apr 2025AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Shri Mani Jain, A/RFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 37(1)

Rs.15,29,095/- Rs.3,94,412/- Rs.26,10,000/- Rs.3,77,96,688/- 5. The AO found that the assessee has booked management fees of Rs.24,00,000/- only as revenue from operations and accordingly showcaused the assessee to explain why the expenses should not be disallowed

Ariston Group India Private Limited, Pune vs. The Assessement Unit, Income Tax Department, NFAC and the DCIT, Circle 1(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1680/PUN/2024[2020-21]Status: DisposedITAT Pune09 Apr 2025AY 2020-21

Bench: Shri R.K.Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1680/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Ariston Group India Private The Assessment Unit, Limited, Income Tax Department, 1St Floor, Office No.103, V National Faceless Mayfai Tower, Wakdewadi, S. Assessment Centre, Shivaji Nagar, Pune-411005. Delhi(“Nfac”), The Dcit, Circle-1(1), Pune. Pan: Aaoca7042D Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 15/01/2025 Date Of Pronouncement 09/04/2025 आदेश/ Order Per Vinay Bhamore, Jm: This Is An Appeal Filed By The Assessee Against The Assessment Order Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961, Dated 18.06.2024 For A.Y.2020- 21. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, Ariston Group India Private Limited (Hereinafter Referred To As "Ariston India' Or 'The Appellant) Prefers An Appeal For The Assessment Year 2020-21 Against

Section 143(3)Section 144Section 144BSection 144C(13)Section 37(1)Section 92C

facts and in the circumstances of the case in determining the arm's length price of the international transaction of payment of management fee as "NIL', thereby making a transfer pricing addition of Rs.6,53,65,772/- to the total income of the Appellant, without appreciating the facts that ... erred in law and on the facts and in circumstances of the case in concluding that the services covered in management fee are largely in the nature of Shareholder activity 6. Erroneous disallowance of Management services fee under section 37(1) of the Act: 6.1 The Ld. AO pursuant

ACIT, Circle-12(2), New Delhi vs. Innovations India Advertising and Event Pvt. Ltd., New Delhi

In the result, appeal of Revenue in ITA No

ITA 534/DEL/2020[2015-16]Status: DisposedITAT Delhi09 Apr 2025AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Alok Bhachawat, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 37(1)

Innovations India [A.Y 2015-16] of the event Rs. 4,22,03,463/- as its Event Management Expense. The assessee declared its Professional Management Fees of Rs. 15,34,500/- as its net revenue. The assessee was asked to furnish details of other expenses claimed in the Profit and Loss ... revenue and, correspondingly, the total budgeted expense of the event (42,203,463) as its event management expense. This effectively reflects the management fees of ₹1,534,500 as net revenue. Reporting of budgeted costs in financials has resulted in higher reporting of revenue and expense

Hari Kishan Rathi, New Delhi vs. ACIT, Central Circle-14, New Delhi

ITA 2566/DEL/2022[2018-19]Status: DisposedITAT Delhi08 Apr 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

Asst. Commissioner of Income-Tax-Circle-6(1)(2), Mumbai vs. Asset Reconstruction Company (India) Ltd., Mumbai

ITA 2127/MUM/2024[2016-17]Status: DisposedITAT Mumbai25 Mar 2025AY 2016-17

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

For Appellant: Shri Dhanesh Bafna &For Respondent: Dr. K.R. Subhash, CIT-DR
Section 3

banks • Subsequently, ARCIL being the sole trustee, manager and recovery agent, manages such NPAs towards recovery and accordingly for such services, ARCIL charges "Management Fees" and "Portfolio Recovery fees" being Trustee and Manager of the trust. This income of ARCIL. is independent and exclusive of any distribution from surplus ... lying in such trusts. • Further, when recovery of NPA takes places, trust first reduces its running cost expenditure from the Realisation including payment of Management fees and Portfolio Recovery fees to ARCIL, and then the balance available funds out of realisation are distributed to all the SRHs which are ARCIL