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...
Rectification u/s 154 - notice u/s 153A - reopening u/s 153A in case of assessee covered u/s 245-I is not provided in the Act - nothing debatable in coming to conclusion that AO’s action in reopening u/s 153A is illegal and not in accordance with law - once when the issue has been decided by the settlement commission, it is not open to the AO to reopen the assessment and consider the issue again
Rectification u/s 154 - notice u/s 153A - reopening u/s 153A in case of assessee covered u/s 245-I is not provided in the Act - nothing debatable in coming to conclusion that AO’s action in reopening u/s 153A is illegal and not in accordance with law - once when the issue has been decided by the settlement commission, it is not open to the AO to reopen the assessment and consider the issue again
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