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...
Royalty income from franchisee hotels - there is no agreement in terms of which the assessee was paid royalty is legally and factually correct, and therefore, the beneficial rate of tax will not apply. - A.O. has rightly charged the tax rate of 15% as given in the DTAA instead of 11.33% - AT
Royalty income from franchisee hotels - there is no agreement in terms of which the assessee was paid royalty is legally and factually correct, and therefore, the beneficial rate of tax will not apply. - A.O. has rightly charged the tax rate of 15% as given in the DTAA instead of 11.33% - AT
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