Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
Disallowance u/s 40A(2)(b) for excessive payments to related concerns was deleted based on CBDT Circular 6-P and case laws of Delhi HC in Sigma Research and Bombay HC in Indo Saudi Services, holding that disallowance is unsustainable when payer and payee are taxed at same rate. ITAT ruled in favour of the assessee.
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