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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Applicability of doctrine of finality and res-judicata - The High Court held that, the principles of res-judicata do not apply squarely for one assessment year to the other. However, in view of the decision of Supreme Court, the High Court held that, keeping in mind the doctrine of finality, unless there is a marked change from one assessment year to the other, the department cannot be allowed to take a different stand.
Applicability of doctrine of finality and res-judicata - The High Court held that, the principles of res-judicata do not apply squarely for one assessment year to the other. However, in view of the decision of Supreme Court, the High Court held that, keeping in mind the doctrine of finality, unless there is a marked change from one assessment year to the other, the department cannot be allowed to take a different stand.
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