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...
Reassessment u/s 147 - assessee's claim of deduction u/s 10B was scrutinized in original proceedings - any attempt on part of AO to reexamine the claim, without any material would be based on change of opinion - clearly impermissible
Reassessment u/s 147 - assessee's claim of deduction u/s 10B was scrutinized in original proceedings - any attempt on part of AO to reexamine the claim, without any material would be based on change of opinion - clearly impermissible
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