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...
Reopening of assessment u/s 147 - Reasons are required to be read as they were recorded by the AO. And that the AO himself must also speak through his reasons and should not keep and also seek through his reasons and should not be an assessee guessing for the same. CIT(A) has rightly accepted the assessee's legal arguments challenging validity of the impugned reassessment. - AT
Reopening of assessment u/s 147 - Reasons are required to be read as they were recorded by the AO. And that the AO himself must also speak through his reasons and should not keep and also seek through his reasons and should not be an assessee guessing for the same. CIT(A) has rightly accepted the assessee's legal arguments challenging validity of the impugned reassessment. - AT
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