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...
Reopening of assessment - Disallowance of deduction claimed u/s 35(1)(ii) - The tribunal upheld the reopening of the assessment, ruling it as a procedural irregularity that does not invalidate the proceedings, and found no merit in the assessee's objections regarding the entitlement to deductions u/s 35(1)(ii), emphasizing the necessity for donations to be made to genuine institutions for claiming such deductions.
Reopening of assessment - Disallowance of deduction claimed u/s 35(1)(ii) - The tribunal upheld the reopening of the assessment, ruling it as a procedural irregularity that does not invalidate the proceedings, and found no merit in the assessee's objections regarding the entitlement to deductions u/s 35(1)(ii), emphasizing the necessity for donations to be made to genuine institutions for claiming such deductions.
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