Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Addition of gift u/s 56(2)(vii) - gift been received by the assessee directly from the uncle - The only reason to treat the same as the income of the assessee is that the amount has been transferred from bank account of uncle’s son and his daughter-in-law who are residing abroad as non-resident. - The gifts so received could be construed as constructive gift from uncle. - Addition deleted - AT
Addition of gift u/s 56(2)(vii) - gift been received by the assessee directly from the uncle - The only reason to treat the same as the income of the assessee is that the amount has been transferred from bank account of uncle’s son and his daughter-in-law who are residing abroad as non-resident. - The gifts so received could be construed as constructive gift from uncle. - Addition deleted - AT
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