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...
Nature of receipt - money received by the assessee for issue of shares but the shares could not be issued due to contravention of FEMA guidelines - AO treated the same as gift by the assessee company or in terms of Section 28(iv) r.w.s. 2(24)(ix) - Alertpay Quebec was not the Holding Company of assessee company. Hence we hold that the observation made by the ld AO in this regard is factually incorrect. - AT
Nature of receipt - money received by the assessee for issue of shares but the shares could not be issued due to contravention of FEMA guidelines - AO treated the same as gift by the assessee company or in terms of Section 28(iv) r.w.s. 2(24)(ix) - Alertpay Quebec was not the Holding Company of assessee company. Hence we hold that the observation made by the ld AO in this regard is factually incorrect. - AT
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