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...
Proceedings u/s. 153C r.w.s. 153A - Recording of satisfaction - CIT (Appeals) not given finding that what basis he came to such conclusion that there was a recording of satisfaction by the Assessing Officer of searched person. We are of the opinion that recording of satisfaction is legal issue which shall be examined by the learned CIT (Appeals) after calling the relevant record from the AO of searched person and decide the issue afresh. - AT
Proceedings u/s. 153C r.w.s. 153A - Recording of satisfaction - CIT (Appeals) not given finding that what basis he came to such conclusion that there was a recording of satisfaction by the Assessing Officer of searched person. We are of the opinion that recording of satisfaction is legal issue which shall be examined by the learned CIT (Appeals) after calling the relevant record from the AO of searched person and decide the issue afresh. - AT
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