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...
The ITAT ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
The ITAT ruled on two issues: 1. Disallowance of Business Promotion Expenses: AO disallowed expenses for a get-together, citing lack of proof of business purpose. CIT(A) upheld, but ITAT found the expenses legitimate due to revenue from operations, accepted expenses, and TDS payment to caterer. AO's disallowance was deemed incorrect. 2. Cessation of Liability u/s 41(1): AO added outstanding professional fees as income u/s 41(1) for being unpaid over 3 years. ITAT disagreed, noting the liability in financial statements indicates intent to settle. Addition was deemed incorrect, and AO was directed to delete it. Assessee's appeal was allowed.
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