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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Rectification of patent errors in GST proceedings is confined to errors apparent on the face of the record and cannot be used to revisit an original determination on under-declared ineligible input tax credit. Where no apparent error is established and supporting documents were not submitted, rejection of a rectification application remains undisturbed. The taxpayer may challenge the original determination independently in accordance with law, rather than seek substantive reconsideration through rectification.
Rectification of patent errors in GST proceedings is confined to errors apparent on the face of the record and cannot be used to revisit an original determination on under-declared ineligible input tax credit. Where no apparent error is established and supporting documents were not submitted, rejection of a rectification application remains undisturbed. The taxpayer may challenge the original determination independently in accordance with law, rather than seek substantive reconsideration through rectification.
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