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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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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
ITAT held that TDS provisions under s.194C apply to transport payments made by assessee to transporters, despite no direct contract between parties. While payments below Rs.50,000 are exempt from TDS per s.194C(5), assessee's claim of Rs.1,00,524 for such payments was allowed. On the broader disallowance under s.40(a)(ia), matter remanded to AO to examine application of amended first proviso limiting disallowance to 30% of expenditure, effective retrospectively from April 1, 2015. Though assessee hadn't previously raised this amendment argument, ITAT permitted fresh consideration by AO for statistical purposes. Ground regarding sub-threshold payments allowed; alternative ground on limited disallowance remanded.
ITAT held that TDS provisions under s.194C apply to transport payments made by assessee to transporters, despite no direct contract between parties. While payments below Rs.50,000 are exempt from TDS per s.194C(5), assessee's claim of Rs.1,00,524 for such payments was allowed. On the broader disallowance under s.40(a)(ia), matter remanded to AO to examine application of amended first proviso limiting disallowance to 30% of expenditure, effective retrospectively from April 1, 2015. Though assessee hadn't previously raised this amendment argument, ITAT permitted fresh consideration by AO for statistical purposes. Ground regarding sub-threshold payments allowed; alternative ground on limited disallowance remanded.
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