Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
TDS u/s 195 - it is proved beyond doubt that the subsidiaries do not have any income chargeable to tax in India - AO directed to delete the disallowance made u/s 40(a)(i) in respect of payments made to foreign subsidiaries.
TDS u/s 195 - it is proved beyond doubt that the subsidiaries do not have any income chargeable to tax in India - AO directed to delete the disallowance made u/s 40(a)(i) in respect of payments made to foreign subsidiaries.
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