Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
The AT set aside the impugned order in FEMA proceedings due to reliance on an unauthenticated foreign document in German pertaining to a foreign trust and bank account. The document, central to the case and originating abroad, was not authenticated as required by law. The appellants denied any knowledge or involvement with the foreign account and trust, and no contradictory evidence was presented by the respondent. The Tribunal reaffirmed its prior ruling that foreign-origin documents lacking proper authentication are inadmissible. Consequently, the order based solely on such document without corroborative evidence was held unsustainable. The appeals were allowed, and the impugned order was quashed for want of merit.
The AT set aside the impugned order in FEMA proceedings due to reliance on an unauthenticated foreign document in German pertaining to a foreign trust and bank account. The document, central to the case and originating abroad, was not authenticated as required by law. The appellants denied any knowledge or involvement with the foreign account and trust, and no contradictory evidence was presented by the respondent. The Tribunal reaffirmed its prior ruling that foreign-origin documents lacking proper authentication are inadmissible. Consequently, the order based solely on such document without corroborative evidence was held unsustainable. The appeals were allowed, and the impugned order was quashed for want of merit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
