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...
Seeking relief u/s 119(2) - condonation of delay in filing return of income - it is impossible to disbelieve the case of the petitioner that the default was due to the circumstances beyond his control. Thus, both the conditions (i) and (ii) of clause (c) of subsection (2) of section 119 of the said Act were fulfilled in the facts of the case. - HC
Seeking relief u/s 119(2) - condonation of delay in filing return of income - it is impossible to disbelieve the case of the petitioner that the default was due to the circumstances beyond his control. Thus, both the conditions (i) and (ii) of clause (c) of subsection (2) of section 119 of the said Act were fulfilled in the facts of the case. - HC
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