Reassessment disclosure requirements permit stated reasons without revealing information sources, but prior-taxation claims require full examination b...
Independent assessment discretion and corroborated electronic evidence determine validity of on-money additions and undisclosed-consideration assessme...
Service of notice and contractual debt acknowledgment preserved insolvency admission against a corporate guarantor despite limitation and natural just...
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
The ITAT held that the comparable company selected by the TPO for transfer pricing adjustment did not match the functional profile of the assessee and thus must be excluded from the comparable set. Regarding other comparables, the tribunal directed the AO/TPO to reconsider their inclusion afresh, applying appropriate filters and providing the assessee a reasonable opportunity to be heard and submit supporting documents. The appeal was partly allowed for statistical purposes, remanding the matter for further examination consistent with the directions.
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