Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
Reopening based on a broker's seized inquiry register failed where the entry did not show a live and direct nexus with the assessee's transaction. The entry was older than the purchase, referred to a larger land area, named another person, and was unsupported by any inquiry linking the assessee to undisclosed consideration. The searched person's statement also indicated that such registers recorded land available for sale, not necessarily actual on-money dealings. On these facts, the material could not justify reopening a later assessment year, and the notice under Section 148 was quashed as unsustainable.
Reopening based on a broker's seized inquiry register failed where the entry did not show a live and direct nexus with the assessee's transaction. The entry was older than the purchase, referred to a larger land area, named another person, and was unsupported by any inquiry linking the assessee to undisclosed consideration. The searched person's statement also indicated that such registers recorded land available for sale, not necessarily actual on-money dealings. On these facts, the material could not justify reopening a later assessment year, and the notice under Section 148 was quashed as unsustainable.
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