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...
Refund claim - Export of services - intermediary services or not - - The activities performed by the petitioner are original activities and for doing the same, it has been charging costs from FKDG. Therefore, it cannot be stated to be intermediary of FKDG and the services provided by it to FKDG cannot be stated to be intermediary services. Thus, a wrong observation has been made by the respondents in this regard. - Refund directed to be processed and allowed - HC
Refund claim - Export of services - intermediary services or not - - The activities performed by the petitioner are original activities and for doing the same, it has been charging costs from FKDG. Therefore, it cannot be stated to be intermediary of FKDG and the services provided by it to FKDG cannot be stated to be intermediary services. Thus, a wrong observation has been made by the respondents in this regard. - Refund directed to be processed and allowed - HC
Note: It is a system-generated summary and is for quick reference only.