Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment u/s 147 -“cause of action” - jurisdiction to this High Court - Appropriate High Court - The writ applicant has a PAN card at such place. The impugned notice under Section 148 of the Act, 1961 was also issued at Cuttack. The return of income for the A. Y. 2015-16 was also filed at Cuttack. The final assessment order dated 29th December 2017 for the A. Y. 2015-16 was also passed at Cuttack. - e should not entertain this writ application and relegate the writ applicant to file an appropriate writ application before the High Court of Orrissa at Cuttack. - HC
Reopening of assessment u/s 147 -“cause of action” - jurisdiction to this High Court - Appropriate High Court - The writ applicant has a PAN card at such place. The impugned notice under Section 148 of the Act, 1961 was also issued at Cuttack. The return of income for the A. Y. 2015-16 was also filed at Cuttack. The final assessment order dated 29th December 2017 for the A. Y. 2015-16 was also passed at Cuttack. - e should not entertain this writ application and relegate the writ applicant to file an appropriate writ application before the High Court of Orrissa at Cuttack. - HC
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