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...
Penalty u/s 271(1)(c) - tax u/s 115JB - assessee’s claim was that it was falling u/s 115JA and duly supported by the certificate of the auditors - If the claim was wrong the responsibility was that of the auditor who duly certified the same - assessee cannot be visited with penalty for the mistake of its consultant/auditor - no penalty
Penalty u/s 271(1)(c) - tax u/s 115JB - assessee’s claim was that it was falling u/s 115JA and duly supported by the certificate of the auditors - If the claim was wrong the responsibility was that of the auditor who duly certified the same - assessee cannot be visited with penalty for the mistake of its consultant/auditor - no penalty
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