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 on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
Penalty on appellant-CHA - abetting in the mis-declaration of the imported goods - the case cannot be built on the basis of vague statement of the co-accused and mere existence of call records - neither any evidence has been found during the search of the Appellant residence nor it is clear whether investigation could reach of the actual importer - penalty without properly establishing his role is not acceptable
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