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...
Reopening of assessment u/s 147 - the duty of the AO is only to primafacie establish that income chargeable to tax has escaped assessment - it would not be his duty to demonstrate with certainty that invariably upon reassessment additions would be stand - HC
Reopening of assessment u/s 147 - the duty of the AO is only to primafacie establish that income chargeable to tax has escaped assessment - it would not be his duty to demonstrate with certainty that invariably upon reassessment additions would be stand - HC
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