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...
Validity of reopening of assessment - Pr. CIT has granted the approval in a mechanical manner by putting only “Yes” which is not valid for initiating the reassessment proceedings. Thereafter, the AO has mechanically issued notice u/s. 148 of the Act. The reopening in the case of the assessee for the asstt. Year in dispute is bad in law and deserves to be quashed. - AT
Validity of reopening of assessment - Pr. CIT has granted the approval in a mechanical manner by putting only “Yes” which is not valid for initiating the reassessment proceedings. Thereafter, the AO has mechanically issued notice u/s. 148 of the Act. The reopening in the case of the assessee for the asstt. Year in dispute is bad in law and deserves to be quashed. - AT
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