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 40A(2)(b) - excessive or unreasonable payments made to specified persons - AO has not done any exercise to determine as to whether the amount paid by the Assessee to the aforesaid two ladies were excessive or unreasonable by comparing the prevalent market rates. He has not arrived at an exact figure of excessive payment by comparing the amount paid by the assessee with the market rates for similar services - ad-hoc disallowance deleted - AT
Disallowance u/s 40A(2)(b) - excessive or unreasonable payments made to specified persons - AO has not done any exercise to determine as to whether the amount paid by the Assessee to the aforesaid two ladies were excessive or unreasonable by comparing the prevalent market rates. He has not arrived at an exact figure of excessive payment by comparing the amount paid by the assessee with the market rates for similar services - ad-hoc disallowance deleted - AT
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