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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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TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency loans advanced to subsidiary. Adjustment in respect of Corporation Bank interest and Allahabad Bank interest deleted as amount was not advanced to AE for entire period. Loan granted to AE out of own funds - matter remitted to AO for readjudication of adjustment of interest. Deduction u/s 35(2AB) - claim for weighted deduction on gross R&D expenditure allowed without reducing contract research income. TP adjustment of corporate guarantee fee - adjustment restricted at 0.5% on guarantee amount. Disallowance u/s 36(1)(iii) - interest free advance - disallowance deleted due to sufficient interest free funds. Excess claim u/s 35(2AB) over DSIR approval - deduction allowed on actual expenditure prior to amendment. Additional claim of weighted deduction u/s 35(2AB) on clinical trial expenses - matter remitted back.
TP adjustment of interest - CIT(A) confirmed upward adjustment towards interest by adopting rupee loan rate instead of LIBOR linked rate in respect of foreign currency loans advanced to subsidiary. Adjustment in respect of Corporation Bank interest and Allahabad Bank interest deleted as amount was not advanced to AE for entire period. Loan granted to AE out of own funds - matter remitted to AO for readjudication of adjustment of interest. Deduction u/s 35(2AB) - claim for weighted deduction on gross R&D expenditure allowed without reducing contract research income. TP adjustment of corporate guarantee fee - adjustment restricted at 0.5% on guarantee amount. Disallowance u/s 36(1)(iii) - interest free advance - disallowance deleted due to sufficient interest free funds. Excess claim u/s 35(2AB) over DSIR approval - deduction allowed on actual expenditure prior to amendment. Additional claim of weighted deduction u/s 35(2AB) on clinical trial expenses - matter remitted back.
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