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...
A delayed duplicate TDS re-deposit was treated as a real revenue loss because the second payment, though made under mistake, was beyond time and the payee had already availed credit; the levy of interest was therefore sustained. By contrast, where the assessee had already deposited TDS and filed Form 26QB within time, the later filing was only a mistaken duplication and not an original default in furnishing the statement; late fee under section 234E was therefore deleted. The appeal was partly allowed.
A delayed duplicate TDS re-deposit was treated as a real revenue loss because the second payment, though made under mistake, was beyond time and the payee had already availed credit; the levy of interest was therefore sustained. By contrast, where the assessee had already deposited TDS and filed Form 26QB within time, the later filing was only a mistaken duplication and not an original default in furnishing the statement; late fee under section 234E was therefore deleted. The appeal was partly allowed.
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