Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
Revisionary review under section 263 was considered on whether the AO failed to inquire into the source of share capital and whether acceptance of a merchant banker valuation was erroneous. The tribunal found the AO had the investor's balance sheet before him, accepted the investor's creditworthiness, and that mere suspicion or association with a group did not amount to lack of inquiry. Inquiry into the source-of-source was not required, and the AO properly accepted a DCF valuation by a qualified merchant banker; revisionary interference was unwarranted and decision favoured the assessee.
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