Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Validity of reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
Validity of reopening/reassessment - The tribunal found that the reasons recorded by the AO for reopening the assessment were not sufficient and valid, as they merely called for detailed verification and enquiry. Relying on the judicial precedents of PCIT vs. Manzil Dinesh Kumar Shah and PCIT vs. Maheswari Devi, the tribunal concluded that such reasons do not meet the statutory requirements for reopening. Consequently, the reassessment was quashed, rendering other issues academic.
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