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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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Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment for sales and marketing function. Port fee charges paid allowed at cost plus 25% markup as per agreement. No adjustment required for administrative support services provided to AE as margin exceeded arm's length price. Addition for brokerage on program trades disallowed as direct third-party transactions without benefitting AEs. Disallowance u/s 14A restricted to assessee's suo motu disallowance due to inapplicability of Rule 8D and availability of surplus interest-free funds. Transfer pricing adjustment on equity broking services (non-DVP/CH segment) remitted for recomputation considering 0.41% as arm's length price after allowing adjustment for sales and marketing function. Disallowance of interest expenses rejected due to availability of sufficient interest-free funds as per Supreme Court decision.
Transfer pricing adjustment on equity broking services (non-DVP segment/CH settlement) rejected due to negligible difference of 0.01% after considering cost adjustment for sales and marketing function. Port fee charges paid allowed at cost plus 25% markup as per agreement. No adjustment required for administrative support services provided to AE as margin exceeded arm's length price. Addition for brokerage on program trades disallowed as direct third-party transactions without benefitting AEs. Disallowance u/s 14A restricted to assessee's suo motu disallowance due to inapplicability of Rule 8D and availability of surplus interest-free funds. Transfer pricing adjustment on equity broking services (non-DVP/CH segment) remitted for recomputation considering 0.41% as arm's length price after allowing adjustment for sales and marketing function. Disallowance of interest expenses rejected due to availability of sufficient interest-free funds as per Supreme Court decision.
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