Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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AO failed to conduct proper inquiries regarding genuineness of loan transactions for property acquisition. Bank statements revealed assessee lacked funds, payments made through loans from two parties. AO accepted evidence without verification, neglecting examination of interest payment, TDS deduction on loans. AO's lack of inquiry rendered order erroneous, prejudicial to revenue interests, justifying CIT's revision u/s 263. Non-application of mind, incorrect assumptions or law application by AO makes order erroneous, prejudicial, validating CIT's revisionary jurisdiction u/s 263. Decided against assessee.
AO failed to conduct proper inquiries regarding genuineness of loan transactions for property acquisition. Bank statements revealed assessee lacked funds, payments made through loans from two parties. AO accepted evidence without verification, neglecting examination of interest payment, TDS deduction on loans. AO's lack of inquiry rendered order erroneous, prejudicial to revenue interests, justifying CIT's revision u/s 263. Non-application of mind, incorrect assumptions or law application by AO makes order erroneous, prejudicial, validating CIT's revisionary jurisdiction u/s 263. Decided against assessee.
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