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...
ITAT ruled against reopening of assessment concerning alleged unaccounted cash loans of Rs.11.05 crore. AO's action based solely on Investigation Wing's information about cash loans through a broker was deemed insufficient for establishing income escapement. The mere receipt of loans cannot constitute income without substantiating evidence of sham transactions. AO failed to discharge the burden of proof after assessee's denial, presenting no corroborating evidence of actual lenders or cash possession. No valuable assets or undisclosed income were discovered with the assessee. The tribunal invalidated the assessment reopening due to lack of tangible material demonstrating income concealment beyond mere information about loan transactions.
ITAT ruled against reopening of assessment concerning alleged unaccounted cash loans of Rs.11.05 crore. AO's action based solely on Investigation Wing's information about cash loans through a broker was deemed insufficient for establishing income escapement. The mere receipt of loans cannot constitute income without substantiating evidence of sham transactions. AO failed to discharge the burden of proof after assessee's denial, presenting no corroborating evidence of actual lenders or cash possession. No valuable assets or undisclosed income were discovered with the assessee. The tribunal invalidated the assessment reopening due to lack of tangible material demonstrating income concealment beyond mere information about loan transactions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4830 
Join Channel 
