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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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Revision u/s 263 - as argued no draft assessment order u/s 144C prior to passing the final assessment order passed - The Tribunal analyzed the circulars cited by the PCIT and concluded that they were explanatory in nature and did not invoke the powers of Section 119 of the Act. As such, non-compliance with these circulars did not render the assessment order erroneous. Moreover, the Tribunal cited precedents to establish that a non-est and void order cannot be subject to revisionary proceedings under Section 263. Therefore, the exercise of jurisdiction by invoking clause (c) of Explanation 2 of Section 263(1) of the Act was deemed inappropriate.
Revision u/s 263 - as argued no draft assessment order u/s 144C prior to passing the final assessment order passed - The Tribunal analyzed the circulars cited by the PCIT and concluded that they were explanatory in nature and did not invoke the powers of Section 119 of the Act. As such, non-compliance with these circulars did not render the assessment order erroneous. Moreover, the Tribunal cited precedents to establish that a non-est and void order cannot be subject to revisionary proceedings under Section 263. Therefore, the exercise of jurisdiction by invoking clause (c) of Explanation 2 of Section 263(1) of the Act was deemed inappropriate.
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