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 - whether Assessment barred by limitation? - Since the burden of establishing the satisfaction of the statutory condition set out in the proviso rests fully upon the Department, and such burden has not been discharged in the present case, the impugned proceedings for reassessment fail. - HC
Reopening of assessment u/s 147 - whether Assessment barred by limitation? - Since the burden of establishing the satisfaction of the statutory condition set out in the proviso rests fully upon the Department, and such burden has not been discharged in the present case, the impugned proceedings for reassessment fail. - HC
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