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 of expenditure - Most importantly, the Tribunal in assessee’s own case for AY 2012- 13 had held that it was not necessary that the business had actually commenced for claiming of expenses but the relevant fact was that the business was set up or not. It is quite evident from the financial statements, that the assessee had already set up its business and was undertaking various projects, the expenditure of which was being accumulated under the head Capital Work-in-progress. Therefore, the observation of Ld. CIT(A) that the business was not set up could not be sustained.
Disallowance of expenditure - Most importantly, the Tribunal in assessee’s own case for AY 2012- 13 had held that it was not necessary that the business had actually commenced for claiming of expenses but the relevant fact was that the business was set up or not. It is quite evident from the financial statements, that the assessee had already set up its business and was undertaking various projects, the expenditure of which was being accumulated under the head Capital Work-in-progress. Therefore, the observation of Ld. CIT(A) that the business was not set up could not be sustained.
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