Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
Non-resident assessee, a regular income tax filer, was subject to best judgment assessment u/s 144 for unexplained investment in mutual funds u/s 69. Assessee submitted additional evidence u/r 46A, which the Assessing Officer and CIT(A) failed to consider properly. ITAT observed assessee is an NRI with income sourced outside India, and the investment was traceable from bank statements. CIT(A) rightly deleted the addition on mutual fund investment and long-term capital gains on sale of equity-oriented mutual funds, being exempt u/s 10(38). ITAT upheld CIT(A)'s order, finding no reason to interfere given the evidence on record.
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