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 allowed the assessee's appeal, deleting additions made u/s 69C and 68. In respect of purchases from the alleged accommodation entry provider, the Tribunal held that the assessee had produced purchase invoices, e-way bills, transport documents, ledger extracts and bank statements evidencing payment through banking channels, and the AO brought no contrary material except a CGST report; the purchases were found to be actually used in manufacturing. For unsecured loans from five creditors, the assessee had filed ITRs, confirmations and bank statements, with no defects identified by AO or CIT(A). Consequently, the CIT(A)'s order was set aside.
ITAT allowed the assessee's appeal, deleting additions made u/s 69C and 68. In respect of purchases from the alleged accommodation entry provider, the Tribunal held that the assessee had produced purchase invoices, e-way bills, transport documents, ledger extracts and bank statements evidencing payment through banking channels, and the AO brought no contrary material except a CGST report; the purchases were found to be actually used in manufacturing. For unsecured loans from five creditors, the assessee had filed ITRs, confirmations and bank statements, with no defects identified by AO or CIT(A). Consequently, the CIT(A)'s order was set aside.
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