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...
Penalty u/s 271(1)(c) - disallowance u/s 40(a)(ia) - The only reason for which the expenditure was disallowed is due to non–deduction of tax at source. In other words, it is statutory disallowance. That being the case, the assessee cannot be accused of submitting inaccurate particulars of income or concealing its income - No penalty - AT
Penalty u/s 271(1)(c) - disallowance u/s 40(a)(ia) - The only reason for which the expenditure was disallowed is due to non–deduction of tax at source. In other words, it is statutory disallowance. That being the case, the assessee cannot be accused of submitting inaccurate particulars of income or concealing its income - No penalty - AT
Note: It is a system-generated summary and is for quick reference only.