Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Penalty u/s 271(1)(c) - surrender of income - suo motu further income declared in the returns filed u/s 153A - Explanation 5A has specific application, the contention of ld. DR. that penalty are sustainable due to the implication of word transaction mentioned in sub clause ii of explanation. 5A cannot be accepted. - AT
Penalty u/s 271(1)(c) - surrender of income - suo motu further income declared in the returns filed u/s 153A - Explanation 5A has specific application, the contention of ld. DR. that penalty are sustainable due to the implication of word transaction mentioned in sub clause ii of explanation. 5A cannot be accepted. - AT
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