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...
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Deemed concealment under Explanation 3 to section 271(1)(c) may apply where a taxpayer files a return only in response to a notice under section 148 and lacks reasonable cause for not filing the original return. However, the tax sought to be evaded must be computed under clause (c) of Explanation 4 after reducing tax deducted at source before the section 148 notice. Where pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded and penalty under section 271(1)(c) is not leviable. The penalty was deleted.
Deemed concealment under Explanation 3 to section 271(1)(c) may apply where a taxpayer files a return only in response to a notice under section 148 and lacks reasonable cause for not filing the original return. However, the tax sought to be evaded must be computed under clause (c) of Explanation 4 after reducing tax deducted at source before the section 148 notice. Where pre-notice tax deducted at source exceeds the final assessed tax liability, no tax is sought to be evaded and penalty under section 271(1)(c) is not leviable. The penalty was deleted.
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