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 statement recorded under section 108 could not sustain penalty because the mandatory procedure under section 138B was not followed, rendering the statement inadmissible for evidentiary reliance. Penalty under section 112(b) also failed because the statutory ingredients were not proved: there was no established dealing with goods liable to confiscation and no of knowledge or reason to believe that the goods were so liable. On these findings, the Tribunal set aside the penalty and allowed the appeal.
A statement recorded under section 108 could not sustain penalty because the mandatory procedure under section 138B was not followed, rendering the statement inadmissible for evidentiary reliance. Penalty under section 112(b) also failed because the statutory ingredients were not proved: there was no established dealing with goods liable to confiscation and no of knowledge or reason to believe that the goods were so liable. On these findings, the Tribunal set aside the penalty and allowed the appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
Join Channel 
