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...
Revival of appellant company - removal of name for non filing of statutory documents for 3 years - The Appellant is in operation as they are entering into MOU’s. The Directors are professionals and to develop an I.T platforms also takes considerable time; it is supplementing “Make in India” programme. No doubt, Company’s business volume is too law but attempting to enter USA Market through MOU is a good sign. All this reflects that the Appellant is in operation. “Operation” in commercial sense means developing business platform also. - Name directed to be restored - AT
Revival of appellant company - removal of name for non filing of statutory documents for 3 years - The Appellant is in operation as they are entering into MOU’s. The Directors are professionals and to develop an I.T platforms also takes considerable time; it is supplementing “Make in India” programme. No doubt, Company’s business volume is too law but attempting to enter USA Market through MOU is a good sign. All this reflects that the Appellant is in operation. “Operation” in commercial sense means developing business platform also. - Name directed to be restored - AT
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