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...
Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by virtue of 2nd proviso to section 153A(1) - once the reassessment proceedings initiated vide notice u/s 148 stood abated by virtue of search and seizure action u/s 132(1) carried out then the reassessment order passed by the AO u/s 147 r.w.s. 143(3) is illegal and void-ab-initio and liable to be quashed. - AT
Validity of the assessment order passed u/s 147 r.w.s. 143(3) - post search assessment - in the case on hand the pending reassessment proceedings u/s 147 got abated by virtue of 2nd proviso to section 153A(1) - once the reassessment proceedings initiated vide notice u/s 148 stood abated by virtue of search and seizure action u/s 132(1) carried out then the reassessment order passed by the AO u/s 147 r.w.s. 143(3) is illegal and void-ab-initio and liable to be quashed. - AT
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