Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reassessment - unaccounted loan received - when AO did not describe how and what manner it came to his knowledge that the assessee receive the accommodation entries, the reopening done by the AO u/s 147 was not valid - AT
Reassessment - unaccounted loan received - when AO did not describe how and what manner it came to his knowledge that the assessee receive the accommodation entries, the reopening done by the AO u/s 147 was not valid - AT
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