Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
The note addresses whether documents seized from a person other than the assessee fall within the phrase 'found in the course of search' and thus may support assessment under section 153A; it records that such material (seized from an employee covered by the same search) is within that scope, but stresses that for an unabated assessment additions under 153A require incriminating material unearthed by the search. The seized document was held non incriminating, and therefore the 153A assessment based on it is invalid; a late challenge to approval and introduction of fresh appellate grounds was rejected for want of record support.
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