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 - addition of AMP expenses - TPO has failed to prove that the real intention of the assessee in incurring advertisement and marketing expenses were to benefit the AE's. and not to promote its own business. Transferring of profit from India, the basic ingredient to invoke the provisions of section 92 of the Act, remains unproved - AT
TPA - addition of AMP expenses - TPO has failed to prove that the real intention of the assessee in incurring advertisement and marketing expenses were to benefit the AE's. and not to promote its own business. Transferring of profit from India, the basic ingredient to invoke the provisions of section 92 of the Act, remains unproved - AT
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