Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expend...
Money-laundering judgment timing requires awaiting the scheduled-offence decision despite continuation of the underlying trial where outcomes directly...
Accredited investor eligibility expands through securities-market exposure, while alternative investment fund disputes require prescribed resolution a...
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The HC affirmed the appellate authority's determination that the assessee's challenge to inclusion of two comparables was unsustainable where the comparables failed the prescribed 75% segment-revenue filter. The court held that, although segment-level financials may establish ALP where authentic and available, it is impermissible to circumvent an explicit selection filter by extracting segment figures when the comparable's relevant segment constitutes less than 75% of total revenue. Consequently the CIT(A)'s exclusion of those comparables stood unassailable and raised no substantial question of law. The assessment adjustment based on the remaining comparable set was thus upheld.
The HC affirmed the appellate authority's determination that the assessee's challenge to inclusion of two comparables was unsustainable where the comparables failed the prescribed 75% segment-revenue filter. The court held that, although segment-level financials may establish ALP where authentic and available, it is impermissible to circumvent an explicit selection filter by extracting segment figures when the comparable's relevant segment constitutes less than 75% of total revenue. Consequently the CIT(A)'s exclusion of those comparables stood unassailable and raised no substantial question of law. The assessment adjustment based on the remaining comparable set was thus upheld.
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