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...
Addition being the income shared with the appellant's spouse - section 5A - Portuguese civil code - in the instant case the appellant was not governed by Portuguese civil code, rather the appellant's spouse though Goan but she loses to be the member of the Portuguese territory, after marrying the appellant who is not the member of the Portuguese territory. Thus, the benefit of the application of section 5A of the income tax act 1961, is not available to the appellant. - AT
Addition being the income shared with the appellant's spouse - section 5A - Portuguese civil code - in the instant case the appellant was not governed by Portuguese civil code, rather the appellant's spouse though Goan but she loses to be the member of the Portuguese territory, after marrying the appellant who is not the member of the Portuguese territory. Thus, the benefit of the application of section 5A of the income tax act 1961, is not available to the appellant. - AT
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