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...
Deduction u/s.80IC - profit attributable to marketing division and brand value to be disallowed or not - CIT(A) has given finding that the same is owned by the foreign collaborator and there cannot be any profit attributable to brand. - disallowing gross profit attributable to marketing and brand value is not correct - AT
Deduction u/s.80IC - profit attributable to marketing division and brand value to be disallowed or not - CIT(A) has given finding that the same is owned by the foreign collaborator and there cannot be any profit attributable to brand. - disallowing gross profit attributable to marketing and brand value is not correct - AT
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