Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Service PE in India - India Singapore DTAA - Service PE or Not - the threshold of the time limit as calculated by the AO from the date of signing of agreement cannot be accepted. - the number of days is far below than 183 days - project does not constitute service PE in India - AT
Service PE in India - India Singapore DTAA - Service PE or Not - the threshold of the time limit as calculated by the AO from the date of signing of agreement cannot be accepted. - the number of days is far below than 183 days - project does not constitute service PE in India - AT
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