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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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CIT jurisdiction u/s 250(4) for direction of verification by Ld. AO. - TP adjustment - In the case in hand, the directions as issued by Ld CIT(A) to the TPO, would in fact would lead to the reopening of reference proceedings, before Ld. TPO, by allowing fresh piece of evidence. Specially, the one, which has not surfaced before any tax authority, so far. - Order of CIT(A) modified - Ld. CIT(A) directed to call for the evidence of assessee at its level and then proceed to decide the matter afresh as per powers u/s 250(4) r.w.s 251(1) of the Act. - AT
CIT jurisdiction u/s 250(4) for direction of verification by Ld. AO. - TP adjustment - In the case in hand, the directions as issued by Ld CIT(A) to the TPO, would in fact would lead to the reopening of reference proceedings, before Ld. TPO, by allowing fresh piece of evidence. Specially, the one, which has not surfaced before any tax authority, so far. - Order of CIT(A) modified - Ld. CIT(A) directed to call for the evidence of assessee at its level and then proceed to decide the matter afresh as per powers u/s 250(4) r.w.s 251(1) of the Act. - AT
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