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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Relief u/s 220(7) - Assessee in default for amount non received in India - From the perusal of the records it can be seen that the compensation is not coming under the purview of the business income as there was no business during the period. - Thus, compensation received in lieu of the losses of the contract which was supposed to be executed in the year 1991 will not form the receipt of revenue in nature, but capital in nature. - Since the amount is not taxable, the question of relief u/s 220(7) becomes redundant - AT
Relief u/s 220(7) - Assessee in default for amount non received in India - From the perusal of the records it can be seen that the compensation is not coming under the purview of the business income as there was no business during the period. - Thus, compensation received in lieu of the losses of the contract which was supposed to be executed in the year 1991 will not form the receipt of revenue in nature, but capital in nature. - Since the amount is not taxable, the question of relief u/s 220(7) becomes redundant - AT
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