Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
ITAT deleted an addition under section 68 where cash deposits were made in a bank account standing in the name of a separately assessed trust, holding that the account did not belong to the assessee but to Deepak Gupta Education Trust. The assessee's role as authorised signatory, together with the affidavit and trust records, showed only representative operation of the account. In the absence of corroborative material establishing beneficial ownership or that the deposits were the assessee's undisclosed income, PAN linkage and signatory status alone were insufficient to sustain the addition in his hands. The Revenue's appeal was dismissed, while the Tribunal made no finding on any possible addition in the hands of the trust.
ITAT deleted an addition under section 68 where cash deposits were made in a bank account standing in the name of a separately assessed trust, holding that the account did not belong to the assessee but to Deepak Gupta Education Trust. The assessee's role as authorised signatory, together with the affidavit and trust records, showed only representative operation of the account. In the absence of corroborative material establishing beneficial ownership or that the deposits were the assessee's undisclosed income, PAN linkage and signatory status alone were insufficient to sustain the addition in his hands. The Revenue's appeal was dismissed, while the Tribunal made no finding on any possible addition in the hands of the trust.
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