Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Onus to prove – the revenue has to prove the existence of a fact that undervaluation of asset was made by the assessee - When that fact is proved, the burden shifts to the assessee to prove otherwise - HC
Onus to prove – the revenue has to prove the existence of a fact that undervaluation of asset was made by the assessee - When that fact is proved, the burden shifts to the assessee to prove otherwise - HC
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