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...
Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
Welfare-fund contribution deductibility depends on comparing the employer's contribution with gross salary, rather than figures distorted by separate accounting of net salaries and combined employee-employer PF and ESI payments. Contributions remaining within the prescribed ceiling are not treated as excess. Disallowance of expenditure relating to exempt income under section 14A read with rule 8D does not arise where no exempt income is earned. Amounts recovered through customer service bills for canteen and transportation facilities used by deputed employees may qualify as business expenditure when incurred wholly and exclusively for the business and supported by customer-bill records.
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