Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment - Correct head of income - LTCG or business income - disallowing indexation on cost of acquisition and treating LTCG as business income - assessee contributed in the form of land in the Joint Development Agreement - the reasons recorded by the Ld AO u/s 148(2) treating the income to chargeable under the head Business and Profession are found to be under wrong appreciation of facts and erroneous application of law, which is not permissible. - AT
Reopening of assessment - Correct head of income - LTCG or business income - disallowing indexation on cost of acquisition and treating LTCG as business income - assessee contributed in the form of land in the Joint Development Agreement - the reasons recorded by the Ld AO u/s 148(2) treating the income to chargeable under the head Business and Profession are found to be under wrong appreciation of facts and erroneous application of law, which is not permissible. - AT
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