Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment u/s 147 - In absense of meeting the mandatory requirement of belongingness of the seized documents with the appellant, the AO was not within his power to invoke the provisions of s. 153C of the Act in the present cases and therefore, in our considered view, the AO rightly dropped the proceedings so initiated u/s. 153C and was statutorily correct in invoking the provisions of s. 148 of the Act. - AT
Reopening of assessment u/s 147 - In absense of meeting the mandatory requirement of belongingness of the seized documents with the appellant, the AO was not within his power to invoke the provisions of s. 153C of the Act in the present cases and therefore, in our considered view, the AO rightly dropped the proceedings so initiated u/s. 153C and was statutorily correct in invoking the provisions of s. 148 of the Act. - AT
Note: It is a system-generated summary and is for quick reference only.