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...
ITAT allowed the assessee the concessional rate under s.115BAA despite non-filing of Form 10-IC before the return due date, holding the form's filing requirement to be directory rather than mandatory. The Tribunal concluded that procedural lapse alone cannot defeat a substantive statutory benefit and directed the Revenue to grant the concessional tax treatment, noting administrative flexibility reflected in earlier CBDT extensions and Tribunal precedents where similar procedural defaults did not disentitle claimants. Result: appeal allowed in favour of the assessee; Revenue directed to compute tax applying s.115BAA and grant consequential relief.
ITAT allowed the assessee the concessional rate under s.115BAA despite non-filing of Form 10-IC before the return due date, holding the form's filing requirement to be directory rather than mandatory. The Tribunal concluded that procedural lapse alone cannot defeat a substantive statutory benefit and directed the Revenue to grant the concessional tax treatment, noting administrative flexibility reflected in earlier CBDT extensions and Tribunal precedents where similar procedural defaults did not disentitle claimants. Result: appeal allowed in favour of the assessee; Revenue directed to compute tax applying s.115BAA and grant consequential relief.
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