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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Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
Section 54EC exemption for long-term capital gains may apply where specified bonds are purchased within six months of transfer across two financial years. For Assessment Year 2013-14, the investment ceiling operated independently for each financial year when the six-month period overlapped them, rather than as a single transaction-wide cap. The later amendment imposing an aggregate cap for the year of transfer and the succeeding financial year did not apply. Accordingly, restricting the exemption to one financial year's ceiling was set aside and the disallowance was deleted.
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