Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Writ application challenging validity of assessment u/s 153C. Unexplained income to be taxed u/s 69A. Appellants instituted statutory appeals before Commissioner of Income Tax (Appeals), raising necessary grounds including jurisdiction aspect. Writ appeals dismissed as appellants impermissibly riding two horses. Observations in previous order not to impede adjudication of appeals as per law. Contention regarding addition of unexplained income u/s 69A to appellants' income found meritorious. Assessing authority to consider unexplained income u/s 69A afresh in accordance with law during de novo assessment, without being bound by previous direction.
Writ application challenging validity of assessment u/s 153C. Unexplained income to be taxed u/s 69A. Appellants instituted statutory appeals before Commissioner of Income Tax (Appeals), raising necessary grounds including jurisdiction aspect. Writ appeals dismissed as appellants impermissibly riding two horses. Observations in previous order not to impede adjudication of appeals as per law. Contention regarding addition of unexplained income u/s 69A to appellants' income found meritorious. Assessing authority to consider unexplained income u/s 69A afresh in accordance with law during de novo assessment, without being bound by previous direction.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
