Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
Revision under section 263 challenged the validity of an exemption claim under section 54 on grounds that the assessing officer failed to examine supporting materials; tribunal found the AO had issued a specific query under section 142(1), the assessee uploaded conveyance deed and supporting evidence in response, and assessment followed that examination. Consequently the reassessment order under section 263 was not sustainable because the assessment was not shown to be erroneous or prejudicial where relevant details were on record and considered. Reliance was placed on prior judicial authority supporting that record-based examination negates the ground for revision.
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