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...
‘Commission Agent’ u/s 65 (105) (zzb) or ‘Business Auxiliary Services’ u/s 65(19)(v) – prima facie there was no scope for a different understanding - the contention to look at the legislative history and read too many words into the legislation to give a different meaning could not be accepted - AT
‘Commission Agent’ u/s 65 (105) (zzb) or ‘Business Auxiliary Services’ u/s 65(19)(v) – prima facie there was no scope for a different understanding - the contention to look at the legislative history and read too many words into the legislation to give a different meaning could not be accepted - AT
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