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...
Disallowance u/s 37(1) - contribution/donation to educational institutions, trust etc. - the disallowance under Explanation 2 to Section 37(1) comes into play only when expenses incurred for discharge of CSR as statutory obligation not on voluntary basis - the correct test should be of commercial expediency and not whether the payment was compulsory for the assessee to make or not - duly allowable
Disallowance u/s 37(1) - contribution/donation to educational institutions, trust etc. - the disallowance under Explanation 2 to Section 37(1) comes into play only when expenses incurred for discharge of CSR as statutory obligation not on voluntary basis - the correct test should be of commercial expediency and not whether the payment was compulsory for the assessee to make or not - duly allowable
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