Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment u/s 147 - Validity of notice issued u/s 148 and 148A(b) - the notice issued under Section 148A(b) of the Act should have clearly brought out the allegations against the petitioner. - Notice and orders are set aside, with liberty to the AO to issue a fresh notice u/s 148A(b) of the Act - HC
Reopening of assessment u/s 147 - Validity of notice issued u/s 148 and 148A(b) - the notice issued under Section 148A(b) of the Act should have clearly brought out the allegations against the petitioner. - Notice and orders are set aside, with liberty to the AO to issue a fresh notice u/s 148A(b) of the Act - HC
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