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...
Addition u/s 68 - genuineness of transactions - Authorities below have not further discharged the onus shifted onto their shoulders to bring on record any positive adverse material against the assessee controverting the documentary evidence filed by the assessee and establishing the fact that the assessee could not substantiate the identity and credit worthiness of loan creditors along with genuineness of transactions and factum of repayment of the alleged creditors. - AT
Addition u/s 68 - genuineness of transactions - Authorities below have not further discharged the onus shifted onto their shoulders to bring on record any positive adverse material against the assessee controverting the documentary evidence filed by the assessee and establishing the fact that the assessee could not substantiate the identity and credit worthiness of loan creditors along with genuineness of transactions and factum of repayment of the alleged creditors. - AT
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