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...
Taxing of the fair market value of the properties owned by AJL u/s 28(iv) - whether the provisions of section 56(2)(viia) is applicable specifically dealing with the shares? - treatment of the transaction of assigning of loan by the AICC to appellant company, whether was a fraudulent transaction or not - the benefit which has arisen as a consequence of adventure in the nature of trade where benefit has been derived in the non-mandatory form i.e.,v in the form of immovable properties of AJL during the year which is taxable u/s 28(iv) and, therefore, it is an income, which has arisen to the assessee, taxable u/s 28(iv). - AT
Taxing of the fair market value of the properties owned by AJL u/s 28(iv) - whether the provisions of section 56(2)(viia) is applicable specifically dealing with the shares? - treatment of the transaction of assigning of loan by the AICC to appellant company, whether was a fraudulent transaction or not - the benefit which has arisen as a consequence of adventure in the nature of trade where benefit has been derived in the non-mandatory form i.e.,v in the form of immovable properties of AJL during the year which is taxable u/s 28(iv) and, therefore, it is an income, which has arisen to the assessee, taxable u/s 28(iv). - AT
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