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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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Power to transfer cases u/s 127 - transfer from Bhopal to Hyderabad - the ground of ostensible variance between the reason assigned for transfer in the show-cause notice and the impugned order of transfer does not actually exist in substance and essentiality. The simple reason being that petitioner knew that the case is being transferred for consolidating the records of the principal contractors and the sub-contractor (petitioner) at one place (Hyderabad). The principle of audi alteram partem thus stands complied with by implication. - The principles of natural justice cannot be applied mechanically. - HC
Power to transfer cases u/s 127 - transfer from Bhopal to Hyderabad - the ground of ostensible variance between the reason assigned for transfer in the show-cause notice and the impugned order of transfer does not actually exist in substance and essentiality. The simple reason being that petitioner knew that the case is being transferred for consolidating the records of the principal contractors and the sub-contractor (petitioner) at one place (Hyderabad). The principle of audi alteram partem thus stands complied with by implication. - The principles of natural justice cannot be applied mechanically. - HC
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