Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Gifts made - the assessee was absolute owner of NDAW upto 24/07/2007 and transferred his 51% shares to RBE and then made the gift to NDAW, in which he still holds 49% stakes, thus, the transfer is covered by exclusion clause u/s 47(XIV) of the Act, consequently, is liable to Gift Tax - AT
Gifts made - the assessee was absolute owner of NDAW upto 24/07/2007 and transferred his 51% shares to RBE and then made the gift to NDAW, in which he still holds 49% stakes, thus, the transfer is covered by exclusion clause u/s 47(XIV) of the Act, consequently, is liable to Gift Tax - AT
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