Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Assessments made under limited scrutiny cannot travel beyond the subject identified in the notice; where the notice was confined to cash deposits, additions on the capital gains exemption claim and treatment of income as business income were invalid. A revised return, once validly filed, replaces the original return; where the Assessing Officer framed the assessment on the basis of the original return while ignoring the revised return, that assessment could not be sustained. The impugned addition was deleted and the appeal was allowed.
Assessments made under limited scrutiny cannot travel beyond the subject identified in the notice; where the notice was confined to cash deposits, additions on the capital gains exemption claim and treatment of income as business income were invalid. A revised return, once validly filed, replaces the original return; where the Assessing Officer framed the assessment on the basis of the original return while ignoring the revised return, that assessment could not be sustained. The impugned addition was deleted and the appeal was allowed.
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