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...
TDS u/s 194C - Disallowance u/s 40(a)(ia) - disallowance of Harbor expenses - although the assessee has filed various details including confirmation from the party and copies of debit notes to prove that it is a reimbursement but not direct expenses incurred by the assessee, the AO simply ignored all the evidences filed by the assessee and made additions - Additions deleted - AT
TDS u/s 194C - Disallowance u/s 40(a)(ia) - disallowance of Harbor expenses - although the assessee has filed various details including confirmation from the party and copies of debit notes to prove that it is a reimbursement but not direct expenses incurred by the assessee, the AO simply ignored all the evidences filed by the assessee and made additions - Additions deleted - AT
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