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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 assessee, a software solution provider, contested various transfer pricing adjustments and disallowances. Key points: Certain comparables were directed to be excluded due to functional differences, size incomparability, and segmental data differences. Economic/working capital adjustment was allowed following precedents. Disallowance u/s 14A read with Rule 8D was partly remitted for re-verification of interest-free funds and nexus with exempt income. Computation of deduction u/s 10A regarding exclusion of foreign currency expenditure and non-exclusion of delayed foreign remittances was restored for re-examination. The levy of interest u/s 234D was remitted for re-verification of refund status.
The assessee, a software solution provider, contested various transfer pricing adjustments and disallowances. Key points: Certain comparables were directed to be excluded due to functional differences, size incomparability, and segmental data differences. Economic/working capital adjustment was allowed following precedents. Disallowance u/s 14A read with Rule 8D was partly remitted for re-verification of interest-free funds and nexus with exempt income. Computation of deduction u/s 10A regarding exclusion of foreign currency expenditure and non-exclusion of delayed foreign remittances was restored for re-examination. The levy of interest u/s 234D was remitted for re-verification of refund status.
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