Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
The ITAT considered the addition of capital gain due to undeclared transaction. The property's ownership was crucial, as the property was not owned by the HUF as claimed. The claim of transfer under HUF partition was rejected as unproven. The "family settlement" theory was introduced late and not supported by evidence. The sale-deed executed was deemed taxable, as it involved a genuine transaction between the assessee and his brothers. The unexplained cash deposits were justified by the Cash-Book, leading to deletion of the addition. Overall, the capital gain addition was upheld, while the unexplained cash deposits addition was deleted.
The ITAT considered the addition of capital gain due to undeclared transaction. The property's ownership was crucial, as the property was not owned by the HUF as claimed. The claim of transfer under HUF partition was rejected as unproven. The "family settlement" theory was introduced late and not supported by evidence. The sale-deed executed was deemed taxable, as it involved a genuine transaction between the assessee and his brothers. The unexplained cash deposits were justified by the Cash-Book, leading to deletion of the addition. Overall, the capital gain addition was upheld, while the unexplained cash deposits addition was deleted.
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