Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Delay of 14 years in adjudication of SCN - Assessee was not knowing that matter was put in the call book - Authorization of Directorate of Revenue Intelligence (DRI) to act as a proper officer - It is at once clear that the period within which the impugned show cause notice was required to be adjudicated has long since elapsed. - Since the period for adjudication of the impugned show cause notice has elapsed, the same cannot be adjudicated. - HC
Delay of 14 years in adjudication of SCN - Assessee was not knowing that matter was put in the call book - Authorization of Directorate of Revenue Intelligence (DRI) to act as a proper officer - It is at once clear that the period within which the impugned show cause notice was required to be adjudicated has long since elapsed. - Since the period for adjudication of the impugned show cause notice has elapsed, the same cannot be adjudicated. - HC
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