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 dominant issue was whether the mandatory prior approval under section 153D was valid, or was granted mechanically without independent application of mind. The forum held that while section 153D does not require detailed reasoning, the approving authority must record at least some indication of independent consideration; here, the approval contained no reasoning and reflected borrowed satisfaction from the AO, defeating the statutory safeguard. Consequently, assessments founded on such void approval were treated as non est in law, and the assessee's appeal was allowed. - ITAT
The dominant issue was whether the mandatory prior approval under section 153D was valid, or was granted mechanically without independent application of mind. The forum held that while section 153D does not require detailed reasoning, the approving authority must record at least some indication of independent consideration; here, the approval contained no reasoning and reflected borrowed satisfaction from the AO, defeating the statutory safeguard. Consequently, assessments founded on such void approval were treated as non est in law, and the assessee's appeal was allowed. - ITAT
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