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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
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 94A - transactions with persons located in notified jurisdictional area - We note with the able assistance of both the parties that the CIT(A) has nowhere dealt with the Assessing Officer’s detailed discussion holding the impugned “CCDs” to be a sham transaction whilst deleting the additions in issue made u/s 94A of the Act. - The assessee’s plea before us is that this entire “sham transactions” issue has become redundant once the CIT(A) holds section 94A itself as not applicable. Be that as it may, we deem it appropriate that the CIT(A) needs to examine and adjudicate the above stated “sham transactions” issue. - AT
Addition u/s 94A - transactions with persons located in notified jurisdictional area - We note with the able assistance of both the parties that the CIT(A) has nowhere dealt with the Assessing Officer’s detailed discussion holding the impugned “CCDs” to be a sham transaction whilst deleting the additions in issue made u/s 94A of the Act. - The assessee’s plea before us is that this entire “sham transactions” issue has become redundant once the CIT(A) holds section 94A itself as not applicable. Be that as it may, we deem it appropriate that the CIT(A) needs to examine and adjudicate the above stated “sham transactions” issue. - AT
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