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Assessee's appeal relates to the addition of Rs. 26,22,23,865, on account of TP adjustment made on payment of management fee to the AE.

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Income Tax Act, 1961 - TDS - The assessee had entered into a borrowing arrangement with Standard Chartered Bank on a net of tax basis. As per the terms of the agreement, the assessee has computed TDS on a net of tax basis and no tax has been separately debited to the P&L a/c. As per the borrowing arrangement, the tax liability, if any, on payment of interest has to be borne by the assessee. Therefore, the tax withheld has to be allowed as expenditure to the assessee. - ASSTT. CIT V/s ANHEUSER BUSCH INBEV INDIA LTD. - [2020] 204 TTJ 402 (ITAT-MUMBAI)

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