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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
The extended period beyond six assessment years for a search assessment under the fourth proviso to section 153A(1) applies only where material available to the Assessing Officer shows escaped income represented by a stipulated asset of the required value. Alleged on-money receipts from project buyers, without a finding that those receipts were represented by such an asset, do not meet that condition. Assessments initiated beyond the six-year period on that basis were void ab initio, and the consequential reassessment orders for the relevant years were invalid.
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