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...
Extended period of limitation - The show-cause notice issued beyond the period of one year from the date of acquiring knowledge is time barred. As there is no allegation in the show-cause notice that appellant caused delay in furnishing information or did not co-operate with the investigation/inquiry, the findings of the Commissioner(Appeals) that the details furnished was insufficient to compute liability is based on mere assumptions. - demand set aside - AT
Extended period of limitation - The show-cause notice issued beyond the period of one year from the date of acquiring knowledge is time barred. As there is no allegation in the show-cause notice that appellant caused delay in furnishing information or did not co-operate with the investigation/inquiry, the findings of the Commissioner(Appeals) that the details furnished was insufficient to compute liability is based on mere assumptions. - demand set aside - AT
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