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...
Additions u/s 41(1) - There cannot be cessation of liability twice - Therefore, when as per Explanation (1) there would be cessation of liability in the FY 2012-13 i.e. relevant to the assessment year 2013-14, the addition for the same cannot be made by presuming remission or cessation of liability in the year under consideration i.e. AY 2007-08 - AT
Additions u/s 41(1) - There cannot be cessation of liability twice - Therefore, when as per Explanation (1) there would be cessation of liability in the FY 2012-13 i.e. relevant to the assessment year 2013-14, the addition for the same cannot be made by presuming remission or cessation of liability in the year under consideration i.e. AY 2007-08 - AT
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