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...
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
Revisional jurisdiction under section 264 extends to relief omitted from a return where a charitable trust later identifies an error causing over-assessment. Voluntary disclosure of income as taxable does not bar reconsideration if the trust disclosed the capital gains and relevant particulars without suppressing material; the revisional authority must examine entitlement under law. For charitable-trust capital gains, reinvestment of net sale consideration in a bank fixed deposit for six months or more is treated as acquisition of another capital asset under Instruction No. 883. Conditions under public-trust law cannot be imported to deny this standalone exemption.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
