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 80-O - Royalty - proof of rendering technical services - Appellant was a managing agent - the principal agent relationship between the parties established - there is no basis for grant of deduction to the Appellant under Section 80-O of the IT Act - SC
Deduction u/s 80-O - Royalty - proof of rendering technical services - Appellant was a managing agent - the principal agent relationship between the parties established - there is no basis for grant of deduction to the Appellant under Section 80-O of the IT Act - SC
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