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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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ITAT adjudicated a tax dispute concerning salary income earned in the United Kingdom. The tribunal rejected the assessee's first contention challenging the CPC's intimation under section 143(1)(a), noting that automated processing does not invalidate adjustments. The tribunal found no merit in the procedural challenge and directed the Jurisdictional Assessing Officer (JAO) to conduct a de novo adjudication. The case was restored for comprehensive reassessment, mandating proper opportunity for the assessee to present details regarding salary income, tax deduction at source, and related issues. Grounds 2-4 were allowed for statistical purposes, with explicit instructions to prevent unnecessary procedural delays.
ITAT adjudicated a tax dispute concerning salary income earned in the United Kingdom. The tribunal rejected the assessee's first contention challenging the CPC's intimation under section 143(1)(a), noting that automated processing does not invalidate adjustments. The tribunal found no merit in the procedural challenge and directed the Jurisdictional Assessing Officer (JAO) to conduct a de novo adjudication. The case was restored for comprehensive reassessment, mandating proper opportunity for the assessee to present details regarding salary income, tax deduction at source, and related issues. Grounds 2-4 were allowed for statistical purposes, with explicit instructions to prevent unnecessary procedural delays.
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