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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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Addition u/s 68 - bogus LTCG on shares - onus to prove - - Despite opportunities provided, the assessee company failed to adequately explain the nature and source of the funds received from the share subscriber companies. This failure to discharge the burden of proof led the A.O. to conclude that the transactions were suspicious. - The assessee company argued that it merely acted as a facilitator for transferring funds to the real beneficiary. However, this contention was not accepted by the ITAT as there was insufficient evidence to prove that the funds were indeed transferred for legitimate purposes. Argument of double taxation also not find favor of the tribunal - Additions confirmed by the tribunal.
Addition u/s 68 - bogus LTCG on shares - onus to prove - - Despite opportunities provided, the assessee company failed to adequately explain the nature and source of the funds received from the share subscriber companies. This failure to discharge the burden of proof led the A.O. to conclude that the transactions were suspicious. - The assessee company argued that it merely acted as a facilitator for transferring funds to the real beneficiary. However, this contention was not accepted by the ITAT as there was insufficient evidence to prove that the funds were indeed transferred for legitimate purposes. Argument of double taxation also not find favor of the tribunal - Additions confirmed by the tribunal.
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