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...
Effective date of a Circular issued by the CBEC - It is not possible to accept the contention advanced on behalf of the department that the circular dated 23.08.2007 is retrospective in nature. The said Circular supersedes all the past Circulars, clarifications and communications on all technical issues. - the Circular dated 23.08.2007 is oppressive in nature and it is a settled principal of law that an oppressive Circular should be given only prospective effect. - AT
Effective date of a Circular issued by the CBEC - It is not possible to accept the contention advanced on behalf of the department that the circular dated 23.08.2007 is retrospective in nature. The said Circular supersedes all the past Circulars, clarifications and communications on all technical issues. - the Circular dated 23.08.2007 is oppressive in nature and it is a settled principal of law that an oppressive Circular should be given only prospective effect. - AT
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