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...
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
Assessee held shares as stock-in-trade for trading purposes, not to earn dividend income. HC held provisions of Section 14A disallowing expenses relatable to exempt income inapplicable as no exempt income accrued. Where shares held as stock-in-trade, earning dividend immaterial; purpose is to trade by selling when price rises to earn profits. Situation differs from holding shares to retain control over investee company and intentionally earning dividend. Decided against revenue.
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