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...
Revision u/s 263 - One has to keep in mind the distinction between “lack of inquiry” and inadequate inquiry”. - If there was any inquiry, even inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 - HC
Revision u/s 263 - One has to keep in mind the distinction between “lack of inquiry” and inadequate inquiry”. - If there was any inquiry, even inadequate that would not by itself give occasion to the Commissioner to pass orders under Section 263 - HC
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