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...
TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT
TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT
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