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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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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
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Suppression of facts or not - Extended period of limitation - The evidences on record do not show that the appellant had acted otherwise than in a bona fide manner - The issue of purported illegal utilization of credit had come to the Department’s knowledge as far back as in the year 2013 while conducting audit - there are no reason to sustain the invocation of extended period of limitation against the appellant. - AT
Suppression of facts or not - Extended period of limitation - The evidences on record do not show that the appellant had acted otherwise than in a bona fide manner - The issue of purported illegal utilization of credit had come to the Department’s knowledge as far back as in the year 2013 while conducting audit - there are no reason to sustain the invocation of extended period of limitation against the appellant. - AT
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