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...
Disallowance of interest - Loans advanced to sister concerns - The Tribunal noted that the Assessee had not appealed against the partial relief granted by the learned CIT (A). - Considering the availability of interest-free funds with the Assessee, the Tribunal upheld the decision of the learned CIT (A) to reduce the interest rate from 16% to 8%.
Disallowance of interest - Loans advanced to sister concerns - The Tribunal noted that the Assessee had not appealed against the partial relief granted by the learned CIT (A). - Considering the availability of interest-free funds with the Assessee, the Tribunal upheld the decision of the learned CIT (A) to reduce the interest rate from 16% to 8%.
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