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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Revision u/s 263 - Since the two properties referred by Ld. PCIT belonged to the partnership firm, the profit on sale of those properties cannot be assessed in the hands of the assessee. When there is no revenue leakage in the hands of the assessee, the impugned assessment order cannot be termed as erroneous and prejudicial to the interests of revenue in respect of this issue. - AT
Revision u/s 263 - Since the two properties referred by Ld. PCIT belonged to the partnership firm, the profit on sale of those properties cannot be assessed in the hands of the assessee. When there is no revenue leakage in the hands of the assessee, the impugned assessment order cannot be termed as erroneous and prejudicial to the interests of revenue in respect of this issue. - AT
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