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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
Shared support cost allocated by a group company was deductible under section 37(1) because the assessee showed actual receipt of services, business benefit, and a reasonable allocation basis. The Tribunal held that disallowance based only on the fact that the expense was centrally incurred and cross-charged was not sustainable, absent concrete material showing the claim was sham, fictitious, inflated, capital, personal, or otherwise inadmissible. Allocation on a workstation basis was treated as a rational and business-oriented key with direct nexus to operations, and no one-to-one correlation of every pooled cost item was required. The addition was deleted.
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