Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
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