Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
The High Court considered the treatment of unsecured loans disallowed in tax assessment at 9% p.a. The ITAT, u/s CIT-Appeals, held that the Respondent explained the transactions satisfactorily. Referring to another ITAT decision, it found the addition to income was based on conjecture. The HC concluded that no substantial legal question was raised for appeal as the evidence supported the Respondent's position. This case did not involve accounting entries disguising transactions, and factual aspects were resolved in favor of the Respondent.
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