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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Addition u/s 68 - A.O. failed to conduct scrutiny of the documents at assessment stage and merely suspected the transaction between the Investors and the assessee. A.O. has also not brought any evidence on record that even if the share applicants did not have the means to make the investments, the investments made by them actually emanated from the coffers of the assessee so as to enable it to be treated as undisclosed income of the assessee. Assessee discharged its initial onus - AT
Addition u/s 68 - A.O. failed to conduct scrutiny of the documents at assessment stage and merely suspected the transaction between the Investors and the assessee. A.O. has also not brought any evidence on record that even if the share applicants did not have the means to make the investments, the investments made by them actually emanated from the coffers of the assessee so as to enable it to be treated as undisclosed income of the assessee. Assessee discharged its initial onus - AT
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