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...
Penalty u/s. 270A - Under-reporting of income / Mis-reporting - Interest income from income tax refunds - After reviewing the submissions and case materials, the Tribunal found that the interest income was indeed disclosed by the taxpayer during the quantum assessment and formed part of the computation submitted. Rejecting the Revenue's request for verification, the Tribunal emphasized that all relevant details were already part of the case file. Relying on legal precedent, the Tribunal concluded that there was no justification for the imposed penalty and proceeded to delete it.
Penalty u/s. 270A - Under-reporting of income / Mis-reporting - Interest income from income tax refunds - After reviewing the submissions and case materials, the Tribunal found that the interest income was indeed disclosed by the taxpayer during the quantum assessment and formed part of the computation submitted. Rejecting the Revenue's request for verification, the Tribunal emphasized that all relevant details were already part of the case file. Relying on legal precedent, the Tribunal concluded that there was no justification for the imposed penalty and proceeded to delete it.
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