Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The assessee disputed the stamp duty value of land purchased, leading to the matter being referred to the District Valuation Officer (DVO). The DVO's valuation, based on comparable cases not objected by the assessee, was adopted as the assessee had not provided any other registered valuer's report. The CIT(A) upheld the addition u/s 56(2)(vii)(b)(ii) for the difference between purchase price and DVO's valuation, as the assessee failed to controvert the findings. The ITAT found no merit in the assessee's grounds and upheld the CIT(A)'s order, deciding against the assessee and confirming the addition u/s 56(2)(vii)(b)(ii).
The assessee disputed the stamp duty value of land purchased, leading to the matter being referred to the District Valuation Officer (DVO). The DVO's valuation, based on comparable cases not objected by the assessee, was adopted as the assessee had not provided any other registered valuer's report. The CIT(A) upheld the addition u/s 56(2)(vii)(b)(ii) for the difference between purchase price and DVO's valuation, as the assessee failed to controvert the findings. The ITAT found no merit in the assessee's grounds and upheld the CIT(A)'s order, deciding against the assessee and confirming the addition u/s 56(2)(vii)(b)(ii).
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