Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Initiation of reassessment proceedings - AO has nowhere brought out as to how the claim of depreciation at higher level in the original assessment proceedings can be construed as failure of the assessee to disclose fully and truly all facts necessary for assessment. It is only change of the opinion by the AO, which in our considered opinion, cannot lead to initiation of reassessment proceedings after a period of four years from the end of the relevant assessment year. - AT
Initiation of reassessment proceedings - AO has nowhere brought out as to how the claim of depreciation at higher level in the original assessment proceedings can be construed as failure of the assessee to disclose fully and truly all facts necessary for assessment. It is only change of the opinion by the AO, which in our considered opinion, cannot lead to initiation of reassessment proceedings after a period of four years from the end of the relevant assessment year. - AT
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