Higher Employee Remuneration Cannot Be Rejected Solely Due to Lower Revenue

ACIT Vs Matrix Power-(Wind) Pvt. Ltd. (ITAT Hyderabad) Transfer Pricing Adjustment Deleted Because PLR Held Appropriate Benchmark for Rupee-Denominated NCDs; Employee Remuneration Allowed Because AO Failed to Prove Expenditure Was Unreasonable or Non-Genuine; No Nexus Between Lower Revenue and Higher Employee Costs, ITAT Upholds Deletion of Disallowance; Rule 46A Objection Rejected Because Supporting Documents Were Not Treated as Additional Evidence. The Income Tax Appellate Tribunal (ITAT), Hyderabad, dismissed the Revenue’s appeal against the order of the Commissioner of Income Tax (...