Section 80JJAA deduction for additional employee cost was...

Section 80JJAA deduction for additional employee cost was allowed to a manpower-services provider because it remained the employer of personnel deployed at customers' premises. Eligible claims for the second and third consecutive years require verification and remain subject to the gross-total-income limit. Chapter VI-A deduction cannot be claimed against income enhanced through an arm's length price adjustment, as the statutory prohibition applies even where the deduction is employee-cost based. Transfer-pricing issues concerning KPO characterisation, Salesforce intra-group service charges, and GAP/GSS programme revenue require fresh examination of functional comparability, supporting documentation, transaction nature and the appropriate pricing method.