Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Transfer pricing adjustments - Supply of hardware to Indian customers – assessee constitutes Permanent Establishment in India in terms of Article 5 of the DTAC- attribution of 50% of profits is justified. - AT
Transfer pricing adjustments - Supply of hardware to Indian customers – assessee constitutes Permanent Establishment in India in terms of Article 5 of the DTAC- attribution of 50% of profits is justified. - AT
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