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 adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT
Transfer pricing adjustment - AO/TPO/DRP not appreciating the 50:50 revenue split business model between the appellant and its associated enterprises in relation to international transactions, i.e. provision and receipt of freight forwarding services, and, further making an upward adjustment alleging that such transactions were not at arm’s length - TNMM v/s CUP method? - AT
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