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...
Deduction u/s 54B - reinvestment of the sale proceeds of the agricultural land - The fact that the agricultural lands were situated within the 8 kilometres from the Municipal Corporation of Pune remain uncontroverted. In the circumstances, the order of the NFAC cannot be sustained in the eyes of law. Thus, the respondent-assessee had failed to discharge the onus of proving that the lands sold were agricultural lands. - Additions made by AO restored - AT
Deduction u/s 54B - reinvestment of the sale proceeds of the agricultural land - The fact that the agricultural lands were situated within the 8 kilometres from the Municipal Corporation of Pune remain uncontroverted. In the circumstances, the order of the NFAC cannot be sustained in the eyes of law. Thus, the respondent-assessee had failed to discharge the onus of proving that the lands sold were agricultural lands. - Additions made by AO restored - AT
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