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...
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
Offence punishable u/s 276CC - failure to file the return of income (ITR) - in the instant case on hand, there is no evasion of tax. It is not the case that no return has been filed. In fact, return has been filed and refund has also been ordered. - there is no willful failure on the part of the petitioner to file return. Therefore, offence u/s 276 CC would not be attracted - HC
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