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...
Grant of satellite rights - the transfer in favour of the assessee is a sale and therefore, excluded from the definition of royalty under sec.9(1) explanation II (5) of the Act – thus, the Tribunal has erred in concluding that the payments made by the appellant are Royalty and not sale - HC
Grant of satellite rights - the transfer in favour of the assessee is a sale and therefore, excluded from the definition of royalty under sec.9(1) explanation II (5) of the Act – thus, the Tribunal has erred in concluding that the payments made by the appellant are Royalty and not sale - HC
Note: It is a system-generated summary and is for quick reference only.