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...
Interest levied by Revenue u/s 234A and 234B - adjustment of cash seized with the tax-liability determined on assessment - the assessee cannot blame Revenue for its own faults in not keeping proper and true record of its own income. The onus and burden is on the assessee to file its return of income in time, which the assessee cannot shift to Revenue merely because an intervening event by way of search and seizure operations have taken place u/s 132(1) of the 1961 Act. - Relief granted for interest u/s 234B but not u/s 234A - AT
Interest levied by Revenue u/s 234A and 234B - adjustment of cash seized with the tax-liability determined on assessment - the assessee cannot blame Revenue for its own faults in not keeping proper and true record of its own income. The onus and burden is on the assessee to file its return of income in time, which the assessee cannot shift to Revenue merely because an intervening event by way of search and seizure operations have taken place u/s 132(1) of the 1961 Act. - Relief granted for interest u/s 234B but not u/s 234A - AT
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