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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Comparable-service valuation under service-tax rules requires comparison between service recipients who stand on the same footing. Flats and a commercial unit allotted without monetary consideration to existing occupants under a redevelopment arrangement could not be valued by reference to sale prices of flats sold to new buyers, because the two recipient groups were not comparable. Since service tax had already been discharged on flats sold to new buyers, the demand based on an assumed value for allotments to existing occupants was unsustainable. The service-tax demand, consequential interest and penalty were set aside.
Comparable-service valuation under service-tax rules requires comparison between service recipients who stand on the same footing. Flats and a commercial unit allotted without monetary consideration to existing occupants under a redevelopment arrangement could not be valued by reference to sale prices of flats sold to new buyers, because the two recipient groups were not comparable. Since service tax had already been discharged on flats sold to new buyers, the demand based on an assumed value for allotments to existing occupants was unsustainable. The service-tax demand, consequential interest and penalty were set aside.
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