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 - original assessment u/s 143(3) - notice u/s 148 after expiry of four years - A bare perusal of the recorded reasons shows that there is no whisper in the reasons recorded that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment - issuance of notice u/s 148(2) as well as order passed u/s147 is bad in law
Reassessment u/s 147 - original assessment u/s 143(3) - notice u/s 148 after expiry of four years - A bare perusal of the recorded reasons shows that there is no whisper in the reasons recorded that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment - issuance of notice u/s 148(2) as well as order passed u/s147 is bad in law
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