Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
A composite assessment order covering more than one tax period was held unsustainable where the court applied its earlier view that a single show-cause notice or assessment order cannot span multiple tax periods once annual return due dates have been reached. The impugned order, which covered several financial years, was set aside on that defect alone. The petitioner had confined the challenge to this point, so the other objections were left open. Fresh proceedings were permitted year-wise, with the intervening period excluded for limitation purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
Join Channel 
