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...
Reopening under Section 148 based on search material requires prima facie evidence showing a live link between the seized document and the assessee; the expressions "pertains to" and "relates to" cannot be read in vacuum. Here, the loose paper predated the assessee's purchase by nearly two years, did not name him, and the broker's statement did not refer to him or establish any connection with the named broker. The alleged on-money inference rested only on external matching of survey details, which was too vague and disconnected to satisfy the jurisdictional threshold. The writ petition was allowed and the reopening notices were quashed.
Reopening under Section 148 based on search material requires prima facie evidence showing a live link between the seized document and the assessee; the expressions "pertains to" and "relates to" cannot be read in vacuum. Here, the loose paper predated the assessee's purchase by nearly two years, did not name him, and the broker's statement did not refer to him or establish any connection with the named broker. The alleged on-money inference rested only on external matching of survey details, which was too vague and disconnected to satisfy the jurisdictional threshold. The writ petition was allowed and the reopening notices were quashed.
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