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...
Conversion of ‘limited scrutiny’ into ‘complete scrutiny’ - to cover the aspect of remuneration to partners - As the ld. CCIT did not make out any case of converting ‘limited scrutiny’ into ‘complete scrutiny’ as a ground for revision, we are afraid that the contention of the ld. DR on this score cannot be entertained. - AT
Conversion of ‘limited scrutiny’ into ‘complete scrutiny’ - to cover the aspect of remuneration to partners - As the ld. CCIT did not make out any case of converting ‘limited scrutiny’ into ‘complete scrutiny’ as a ground for revision, we are afraid that the contention of the ld. DR on this score cannot be entertained. - AT
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