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...
ESOP expenses - non deduction of tds on discount given- assessee has vested ESOP rights to certain employees - there will be time different between “vesting of option” and “exercise of option” - the tax authorities are not justified in holding that the assessee should have deducted tax at source from the discount amount by assessing the same as perquisite in the hands of the assessee in the year in which ESOP was vested in them. - AT
ESOP expenses - non deduction of tds on discount given- assessee has vested ESOP rights to certain employees - there will be time different between “vesting of option” and “exercise of option” - the tax authorities are not justified in holding that the assessee should have deducted tax at source from the discount amount by assessing the same as perquisite in the hands of the assessee in the year in which ESOP was vested in them. - AT
Note: It is a system-generated summary and is for quick reference only.