Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Validity of reassessment under section 147 turned on whether the AO acted on tangible information and applied independent mind rather than on borrowed satisfaction; the Tribunal held that specific information about substantial cash capital introduction, considered against low returned income and material on record, satisfied the prima facie belief threshold required for reopening. The Tribunal further upheld treating the cash capital introduction as unexplained investment under section 69, placing onus on the assessee to prove the source. Conclusion: reassessment initiation and the addition under section 69 were sustained and the appeal was dismissed by ITAT.
Validity of reassessment under section 147 turned on whether the AO acted on tangible information and applied independent mind rather than on borrowed satisfaction; the Tribunal held that specific information about substantial cash capital introduction, considered against low returned income and material on record, satisfied the prima facie belief threshold required for reopening. The Tribunal further upheld treating the cash capital introduction as unexplained investment under section 69, placing onus on the assessee to prove the source. Conclusion: reassessment initiation and the addition under section 69 were sustained and the appeal was dismissed by ITAT.
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