Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Revision u/s 264 in favor of assessee - the appeal of the Assessee has not been disposed on merits. In view of this, there was no bar to the CIT in exercising jurisdiction u/s.264 - the embargo imposed in Sec. 264 that there should be no appeal pending before CIT(A) on the issues raised in the application u/s.264 is not applicable in the present case - AT
Revision u/s 264 in favor of assessee - the appeal of the Assessee has not been disposed on merits. In view of this, there was no bar to the CIT in exercising jurisdiction u/s.264 - the embargo imposed in Sec. 264 that there should be no appeal pending before CIT(A) on the issues raised in the application u/s.264 is not applicable in the present case - AT
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