Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Low household withdrawals were treated as unjustified where the assessee showed substantially lower withdrawals than in the preceding year and produced no evidence that the spouse met household expenses, so the Revenue's estimation was upheld. Year-end trade and expense creditors were not assessable as unexplained cash credits under section 68 because the assessment accepted the transaction credits but rejected only the unpaid balances without reason, and the outstanding amounts were later paid through banking channels. Freight expenditure was disallowed under section 40(a)(ia) because tax had not been deducted at source and the transporters' declarations under section 194C(6) were incomplete and appeared afterthoughts, so the disallowance was sustained.
Low household withdrawals were treated as unjustified where the assessee showed substantially lower withdrawals than in the preceding year and produced no evidence that the spouse met household expenses, so the Revenue's estimation was upheld. Year-end trade and expense creditors were not assessable as unexplained cash credits under section 68 because the assessment accepted the transaction credits but rejected only the unpaid balances without reason, and the outstanding amounts were later paid through banking channels. Freight expenditure was disallowed under section 40(a)(ia) because tax had not been deducted at source and the transporters' declarations under section 194C(6) were incomplete and appeared afterthoughts, so the disallowance was sustained.
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