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 HC dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
The HC dismissed the petitioner's writ insofar as it sought premature interference with the respondent's tax notice, holding that the petitioner failed to file the requisite reply to the impugned notice dated 18.03.2025 and thus cannot seek relief before the Court without exhausting the statutory process. The Court found that the petitioner bears the evidentiary burden to substantiate entitlement to the lower TDS rate where the seller's PAN was not linked to Aadhaar at the relevant time. The HC directed the Petitioner to file a substantive reply with supporting documents within two weeks of receipt of this order, and directed the Respondent to consider that reply and pass a decision expeditiously.
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