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...
Approved insolvency resolution plan waivers of indirect-tax liabilities did not extend to GST liabilities arising after 1 April 2022. The cited Supreme Court precedent on the binding effect of resolution plans was inapplicable on the stated facts, while a High Court ruling was identified as clarifying the position. The challenge based on the resolution plan was not accepted; the taxpayer could pursue the statutory appeal on meeting the prescribed pre-deposit requirement.
Approved insolvency resolution plan waivers of indirect-tax liabilities did not extend to GST liabilities arising after 1 April 2022. The cited Supreme Court precedent on the binding effect of resolution plans was inapplicable on the stated facts, while a High Court ruling was identified as clarifying the position. The challenge based on the resolution plan was not accepted; the taxpayer could pursue the statutory appeal on meeting the prescribed pre-deposit requirement.
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