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...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
Addition treated as unexplained cash credit on an unsecured loan was deleted because the lender's identity, creditworthiness based on its financials, and the genuineness of the loan transaction from an NBFC had already been accepted on identical facts in a coordinate Bench decision. The Tribunal held that the Commissioner (Appeals) had sustained the addition mainly by relying on an order in a group concern's case involving the same lender, but that foundation no longer survived after the earlier order was reversed. Applying the same reasoning, the loan from M/s Sundram Consultants Pvt. Ltd. was not liable to be assessed as unexplained cash credit.
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