In the result, the appeal for assessment year 2011-2012
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
2) of the Act. 7.6 On the facts and in the circumstances of the case, the learned ACIT and DRP have erred in law by confirming the disallowance of management fees paid by the Appellant to USTR, under section 40(a)(i) of the Act, on the grounds of perceived non- withholding of tax at source under section