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...
Penalty u/s 271(1)(c) - income declared duty survey - voluntary delcaration or not - it is not a case wherein a disclosure was voluntarily made, indeed the assessee accepted the differential amount of business profit earned by him only after the same was brought to surface owing to survey action u/s 133A otherwise actual business profits would have remained un-assessed and untaxed, if survey action could not have taken place - Penalty sustained - AT
Penalty u/s 271(1)(c) - income declared duty survey - voluntary delcaration or not - it is not a case wherein a disclosure was voluntarily made, indeed the assessee accepted the differential amount of business profit earned by him only after the same was brought to surface owing to survey action u/s 133A otherwise actual business profits would have remained un-assessed and untaxed, if survey action could not have taken place - Penalty sustained - AT
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