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...
Section 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.
Section 260A confines High Court interference with Tribunal findings on rejection of books, income estimation and fee refunds to cases of perversity, lack of evidentiary support or legal error. Where seized material, account books and submissions require factual examination, alternative computations do not themselves create a substantial question of law. Once books are rejected, income and allowable fee refunds may be determined by estimation. The Tribunal may examine the basis and extent of fee-refund relief when the Revenue challenges that relief and the assessee files a cross-objection concerning the sustained addition; this remains within its appellate jurisdiction.
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