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...
Additions u/s 68 - Low profit ratio - the assessee has discharged his onus before the revenue authorities. AO and the ld. CIT(A) rejected the explanation of the assessee solely based on the limited issue of low profit - There were no enquiries made nor any evidence to reject the documents/evidences filed by the assessee - AT
Additions u/s 68 - Low profit ratio - the assessee has discharged his onus before the revenue authorities. AO and the ld. CIT(A) rejected the explanation of the assessee solely based on the limited issue of low profit - There were no enquiries made nor any evidence to reject the documents/evidences filed by the assessee - AT
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