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...
Maintainability of writ petition - The High court held that the 1st respondent company, being a Public Sector Undertaking with the majority of its shares held by government entities and subject to significant government control, qualifies as an "instrumentality of the Union of India" under Article 12 of the Constitution. Therefore, it is amenable to writ jurisdiction, overturning the previous judgment that deemed the writ petition not maintainable.
Maintainability of writ petition - The High court held that the 1st respondent company, being a Public Sector Undertaking with the majority of its shares held by government entities and subject to significant government control, qualifies as an "instrumentality of the Union of India" under Article 12 of the Constitution. Therefore, it is amenable to writ jurisdiction, overturning the previous judgment that deemed the writ petition not maintainable.
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