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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Revision petition u/s. 264 - disallowance of carry forward of loss to subsequent years - CIT while disposing of the 264 petition of the assessee, had clearly directed the ld. AO to treat the return filed by the assessee originally as a valid return - AO while giving effect to the proceedings of the ld. CIT should not have travelled beyond the directions given by the ld. CIT. The ld. AO should have simply treated the return filed by the assessee originally and accepted the same without resorting to make any disallowances thereon. - AT
Revision petition u/s. 264 - disallowance of carry forward of loss to subsequent years - CIT while disposing of the 264 petition of the assessee, had clearly directed the ld. AO to treat the return filed by the assessee originally as a valid return - AO while giving effect to the proceedings of the ld. CIT should not have travelled beyond the directions given by the ld. CIT. The ld. AO should have simply treated the return filed by the assessee originally and accepted the same without resorting to make any disallowances thereon. - AT
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