Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Penalty u/s 77(2) & 78 of the Finance Act, 1994 - The issue is a bonafide dispute of legal interpretation of the newly introduced provision coupled with transaction concerning availment of such services has been reflected in ST-I monthly return, no malafide can be attributed to the assessee to call for imposition of penalty of any kind - penalty set aside.
Penalty u/s 77(2) & 78 of the Finance Act, 1994 - The issue is a bonafide dispute of legal interpretation of the newly introduced provision coupled with transaction concerning availment of such services has been reflected in ST-I monthly return, no malafide can be attributed to the assessee to call for imposition of penalty of any kind - penalty set aside.
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