Section 153A Assessment Finds No Evidence Linking Foreign Receipts to Services in India; Income Assumed Without Proof.

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....Assessment u/s 153A - there is nothing which can lead to any inference or the conclusion that the receipts from foreign companies were in relation to services rendered by the assessee to Fedrigoni in India. Thus, even the FTTR reference cannot be considered as material on record to support the case made out by the Assessing Officer, which goes to prove that his assessment of income was purely based on surmises and presumptions - AT....