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...
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
Initiation of contempt proceedings by issuance of a show cause notice does not ordinarily create an appealable right because it does not adjudicate substantial rights; accordingly the appellate forum declined to entertain the appeal against the notice but granted liberty to the respondent to file a reply to the notice before the tribunal. An interim disclosure direction concerning transactions was treated as superseded and its subject matter subsumed in a pending substantive appeal, so the separate appeal on that disclosure was dismissed as unnecessary and related pending applications were disposed of.
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