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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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Deduction u/s 80IC - AO reallocated management fees and remuneration paid to managing director on gross profit basis. ITAT held allocation basis accepted by AO in past assessment years must be followed as per rule of consistency, directing AO to accept assessee's basis of allocation. Set off of loss of non-eligible unit against profit of eligible unit for computing deduction u/s 80IC - Following precedents, ITAT directed AO to allow deduction @30% on eligible unit's profit without setting off losses from other units, overriding provisions of sub-s. (7) of s. 80-IA prohibiting such set-off.
Deduction u/s 80IC - AO reallocated management fees and remuneration paid to managing director on gross profit basis. ITAT held allocation basis accepted by AO in past assessment years must be followed as per rule of consistency, directing AO to accept assessee's basis of allocation. Set off of loss of non-eligible unit against profit of eligible unit for computing deduction u/s 80IC - Following precedents, ITAT directed AO to allow deduction @30% on eligible unit's profit without setting off losses from other units, overriding provisions of sub-s. (7) of s. 80-IA prohibiting such set-off.
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