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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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Validity of SCN - time limitation - The Court then takes note of Section 28(9A)(c) and which is the principal provision which is sought to be invoked by the respondents in order to save the SCNs’ which have been impugned. Clause (c) speaks of SCN proceedings being kept pending in light of directions that may be issued by the Board. It significantly employs the phrases “similar matter”, “specific direction” and “such matter”. - The proceedings initiated against the present petitioners cannot be said to be covered under the directives of the Board. Those SCNs’ would also not fall within the ambit of Section 28(9A)(c). - SCN quashed as period of limitation expired - HC
Validity of SCN - time limitation - The Court then takes note of Section 28(9A)(c) and which is the principal provision which is sought to be invoked by the respondents in order to save the SCNs’ which have been impugned. Clause (c) speaks of SCN proceedings being kept pending in light of directions that may be issued by the Board. It significantly employs the phrases “similar matter”, “specific direction” and “such matter”. - The proceedings initiated against the present petitioners cannot be said to be covered under the directives of the Board. Those SCNs’ would also not fall within the ambit of Section 28(9A)(c). - SCN quashed as period of limitation expired - HC
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