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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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The review petition challenges the order imposing interest liability over the withheld amount and cost on the Managing Director. The court held that reviewing an order is limited and can only be done under specific conditions laid down by the Supreme Court. Regarding the interest liability, the court found no ambiguity as it was based on the applicable regulations. Challenging this would amount to an appeal rather than a review. As for the cost imposed on the Managing Director, the court held that even if it was a wrong consideration, it cannot be a ground for review but an appeal. If the Managing Director was not a party, his individual liability cannot be questioned by others. Applying the principles for reviewing orders, the court dismissed the review petition.
The review petition challenges the order imposing interest liability over the withheld amount and cost on the Managing Director. The court held that reviewing an order is limited and can only be done under specific conditions laid down by the Supreme Court. Regarding the interest liability, the court found no ambiguity as it was based on the applicable regulations. Challenging this would amount to an appeal rather than a review. As for the cost imposed on the Managing Director, the court held that even if it was a wrong consideration, it cannot be a ground for review but an appeal. If the Managing Director was not a party, his individual liability cannot be questioned by others. Applying the principles for reviewing orders, the court dismissed the review petition.
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