Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
The HC allowed the writ petition, holding that the AO possessed sufficient material to initiate reassessment proceedings under s.148 read with s.148A(1) and to frame an order under s.143A(3); the impugned action was taken pursuant to information generated under the CBDT's Risk Management Strategy recognised by s.148(3)(i). The court rejected the AO's inference that liquidation of a counterparty (hereinafter "Entity X") amounted to proof of a bogus concern, noting that subsequent acquisition of Entity X evidenced commercial legitimacy and that liquidation alone cannot justify a presumption of sham transactions. It was also noted that no complaint of denial of hearing under s.148A(1) was made.
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