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...
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
Scope of rectification of mistake - The case revolved around the disallowance of EPF and ESI contributions by the Assessing Officer u/s 154 of the Income-tax Act, 1961. The key contention was whether the AO was justified in exercising rectification powers under Section 154 due to conflicting judgments and the absence of a clear error apparent on record. The Appellate Tribunal ruled in favor of the assessee, holding that the AO's action was not justified as the issue was debatable and there was no clear error evident at the time of the original assessment.
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