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) - the fact that the assessee and his son have declared the undisclosed income in their individual return of income and have paid taxes but capital expenditure and payment towards purchase of land cannot be held as undisclosed income in the hands of the assessee - no penalty under explanation 5A to section 271(1)(c) unless assessee is owner of the undisclosed income
Penalty u/s 271(1)(c) - the fact that the assessee and his son have declared the undisclosed income in their individual return of income and have paid taxes but capital expenditure and payment towards purchase of land cannot be held as undisclosed income in the hands of the assessee - no penalty under explanation 5A to section 271(1)(c) unless assessee is owner of the undisclosed income
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