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...
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
Jurisdiction assumed by DCIT not challenged within stipulated period, hence cannot be questioned now. Addition u/s 68 not sustainable as summary of receipts discloses names, addresses, and telephone numbers of donors with specific directions for contributions. Matter remanded to verify authenticity of summary receipts and copies of receipts issued. Notice u/s 143(2) issued prior to intimation u/s 143(1) valid as per Supreme Court ruling in CIT vs. Gujarat Electricity Board case, where processing u/s 143(1) subsequent to notice u/s 143(2) does not invalidate the notice.
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