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...
Payment is on account of compensation not to M/s. Khaitan & Co. but to M/s. Services & Supplies India and this is not a legal fee necessitating deduction of tax at source as prescribed u/s. 194J of the Act. Once the provisions of section 194J of the Act are not attracted, the disallowance cannot be made u/s 40(a)(ia) - AT
Payment is on account of compensation not to M/s. Khaitan & Co. but to M/s. Services & Supplies India and this is not a legal fee necessitating deduction of tax at source as prescribed u/s. 194J of the Act. Once the provisions of section 194J of the Act are not attracted, the disallowance cannot be made u/s 40(a)(ia) - AT
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