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...
Penalty u/s. 271AAB - The assessees’ sole substantive grievance appears to be that the AO’s corresponding show cause notices dated 29.12.2017 (supra) had not been validly issued. We find no merit in the assessees’ stand once it has come on record that the impugned penalty has been levied @ 10% since falling in the first and foremost limb u/sec. 271AAB(1)(a)(i) to (iii) of the Act in the specified circumstances. - AT
Penalty u/s. 271AAB - The assessees’ sole substantive grievance appears to be that the AO’s corresponding show cause notices dated 29.12.2017 (supra) had not been validly issued. We find no merit in the assessees’ stand once it has come on record that the impugned penalty has been levied @ 10% since falling in the first and foremost limb u/sec. 271AAB(1)(a)(i) to (iii) of the Act in the specified circumstances. - AT
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