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...
Revision u/s 263 by CIT - since the assessee failed to deduct tax, the A.O was required to make disallowance of interest u/s 40(a)(ia) of the Act on account of non-deduction of TDS. A.O also did not notice that STDR with SBI is not a long term specified asset within the meaning of sec. 54EC of the Act and allowed the claim of the assessee without going through the facts. Therefore, the order passed by the A.O is erroneous and prejudicial to the interest of revenue. - AT
Revision u/s 263 by CIT - since the assessee failed to deduct tax, the A.O was required to make disallowance of interest u/s 40(a)(ia) of the Act on account of non-deduction of TDS. A.O also did not notice that STDR with SBI is not a long term specified asset within the meaning of sec. 54EC of the Act and allowed the claim of the assessee without going through the facts. Therefore, the order passed by the A.O is erroneous and prejudicial to the interest of revenue. - AT
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