https://www.taxtmi.com/caselaws?id=798096 Section 80JJAA deduction applies where the entity retains substantive authority over appointment, remuneration, deployment, discipline and termination of personnel; customer operational supervision does not negate employer status. A one-day delay in filing Form 10DA is condonable, while second- and third-year claims require verification. The first proviso to section 92C(4) bars Chapter VI-A deductions, including section 80JJAA, from income enhanced by an arm's length price adjustment. Transfer-pricing determinations involving KPO characterisation, functional comparables with segmental data, intra-group service charges including Salesforce allocation, and GAP/GSS programme revenue require examination of supporting material and fresh arm's length price determination. en-us Tue, 25 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798096 Section 80JJAA deduction applies where the entity retains substantive authority over appointment, remuneration, deployment, discipline and termination of personnel; customer operational supervision does not negate employer status. A one-day delay in filing Form 10DA is condonable, while second- and third-year claims require verification. The first proviso to section 92C(4) bars Chapter VI-A deductions, including section 80JJAA, from income enhanced by an arm's length price adjustment. Transfer-pricing determinations involving KPO characterisation, functional comparables with segmental data, intra-group service charges including Salesforce allocation, and GAP/GSS programme revenue require examination of supporting material and fresh arm's length price determination. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798096