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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Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
Misreporting of income under section 270A is not established merely because a donation deduction claimed under section 80GGC was disclosed in the return and later disallowed or withdrawn in a reassessment return. Misreporting requires material indicating deliberate furnishing of inaccurate particulars, false evidence, suppression, or misrepresentation. Where the taxpayer fulfils the substantive conditions for immunity under section 270AA(1), penalty protection applies. On these principles, the penalty imposed for misreporting was deleted and the appeal was allowed.
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