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 case pertains to the estimation of income and disallowance of bogus purchases. The purchases were deemed sham transactions fabricated through bogus paper concerns engaged in providing accommodation entries. The Income Tax Appellate Tribunal (ITAT) partly allowed the Revenue's appeal, holding that for bogus purchases, the addition at the rate of 6% of the bogus purchases was fair and reasonable. The High Court upheld the ITAT's view, stating that the conclusion was based on the material and analysis of facts and figures available. The court found no substantial questions of law arising from the ITAT's decision to reduce the disallowance from 12.5% to 6% for the bogus purchases.
The case pertains to the estimation of income and disallowance of bogus purchases. The purchases were deemed sham transactions fabricated through bogus paper concerns engaged in providing accommodation entries. The Income Tax Appellate Tribunal (ITAT) partly allowed the Revenue's appeal, holding that for bogus purchases, the addition at the rate of 6% of the bogus purchases was fair and reasonable. The High Court upheld the ITAT's view, stating that the conclusion was based on the material and analysis of facts and figures available. The court found no substantial questions of law arising from the ITAT's decision to reduce the disallowance from 12.5% to 6% for the bogus purchases.
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