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...
TP Adjustment - non speaking order - silent in considering submissions of the assessee - the ld.CIT(A) reproduced 40 pages of written submission given by the assessee, and thereafter concluded the finding in five-six lines - it is apparent that such finding does not contain any adjudication on the submissions of the assessee and not sustainable
TP Adjustment - non speaking order - silent in considering submissions of the assessee - the ld.CIT(A) reproduced 40 pages of written submission given by the assessee, and thereafter concluded the finding in five-six lines - it is apparent that such finding does not contain any adjudication on the submissions of the assessee and not sustainable
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