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...
Revision u/s 263 - deduction claimed towards R&D expenditure incurred for Bio-pharma division - AO without considering relevant facts simply allowed the claim of the assessee. Therefore, in our considered view, the assessment order passed by the AO is erroneous and also prejudicial to the interest of the revenue, because the AO failed to carry out required inquires or verifications which should have been made in the given facts and circumstances of the case. - AT
Revision u/s 263 - deduction claimed towards R&D expenditure incurred for Bio-pharma division - AO without considering relevant facts simply allowed the claim of the assessee. Therefore, in our considered view, the assessment order passed by the AO is erroneous and also prejudicial to the interest of the revenue, because the AO failed to carry out required inquires or verifications which should have been made in the given facts and circumstances of the case. - AT
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