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...
Revision u/s 264 in favor of assessee - period of limitation - the petitioner cannot be shut out from placing facts before the Commissioner and Section 264 empowers the Commissioner to cause enquiry and verify the facts. Secondly, if there has been a genuine mistake committed by the assessee, Statute does not bar the assessee from rectifying his mistake - HC
Revision u/s 264 in favor of assessee - period of limitation - the petitioner cannot be shut out from placing facts before the Commissioner and Section 264 empowers the Commissioner to cause enquiry and verify the facts. Secondly, if there has been a genuine mistake committed by the assessee, Statute does not bar the assessee from rectifying his mistake - HC
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