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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Short Term Capital Gain arising out of transfer of equity shares - FCCBs/GDRs which were subsequently converted to equity shares - cost of acquisition of underlying shares - whether capital gain has to be computed by adopting the cost of acquisition of the GDRs/FCCBs under clause 7(3) and 7(4) of the 1993 scheme or it has to be computed under section 49(2A) r.w.s. 47(x) and 47(xa) of the Act, as held by the Departmental Authorities? - To be computed as per the clause 7(3) and 7(4) of the 1993 scheme - AT
Short Term Capital Gain arising out of transfer of equity shares - FCCBs/GDRs which were subsequently converted to equity shares - cost of acquisition of underlying shares - whether capital gain has to be computed by adopting the cost of acquisition of the GDRs/FCCBs under clause 7(3) and 7(4) of the 1993 scheme or it has to be computed under section 49(2A) r.w.s. 47(x) and 47(xa) of the Act, as held by the Departmental Authorities? - To be computed as per the clause 7(3) and 7(4) of the 1993 scheme - AT
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