Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Rectification of mistake u/s 254 - Penalty is levied in the instant case under Section 271(1)(i)(a) of the Act (as it then stood), while the explanation applies to the cases covered by Section 271(1)(i)(b) of the Act (as it then stood). Viewed in the above light also, we are of the view that the rectification petition could not have been allowed by the Tribunal. - HC
Rectification of mistake u/s 254 - Penalty is levied in the instant case under Section 271(1)(i)(a) of the Act (as it then stood), while the explanation applies to the cases covered by Section 271(1)(i)(b) of the Act (as it then stood). Viewed in the above light also, we are of the view that the rectification petition could not have been allowed by the Tribunal. - HC
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