Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment - non deduction of tds on payment credit to foreign companies, on account of ‘software services‘ - there remained no omission or failure on the part of the assessee to disclose truly and fully all material facts - reassessment proceedings set aside - HC
Reopening of assessment - non deduction of tds on payment credit to foreign companies, on account of ‘software services‘ - there remained no omission or failure on the part of the assessee to disclose truly and fully all material facts - reassessment proceedings set aside - HC
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