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...
Taxability of amount received - PE in India - DTAA - whether payments made by the assessee’s customers to it constituted royalty, in respect of software supplied? - supply of software, in the nature of articles or goods. - The mere fact that separate invoicing was done for purchase and other transactions did not imply that it was royalty payment - HC
Taxability of amount received - PE in India - DTAA - whether payments made by the assessee’s customers to it constituted royalty, in respect of software supplied? - supply of software, in the nature of articles or goods. - The mere fact that separate invoicing was done for purchase and other transactions did not imply that it was royalty payment - HC
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