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...
Accrual of income - effect of addendum of agreement - merely because in the original agreement, the parties had agreed to a higher sum by way of sale consideration, such amount cannot be stated to have accrued to the assessee, ignoring later developments reducing consideration due to slum in the business - income accrued based on revised terms.
Accrual of income - effect of addendum of agreement - merely because in the original agreement, the parties had agreed to a higher sum by way of sale consideration, such amount cannot be stated to have accrued to the assessee, ignoring later developments reducing consideration due to slum in the business - income accrued based on revised terms.
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