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...
Transfer pricing adjustment - TPO made an adjustment taking in to consideration the OP/OC for AE segment at 23% [26%(-)3%,an allowance for delay in receivables and after sales services and other efforts made under the non-AE business] - some reasonable comparables should be selected after considering the FAR analysis of such comparable and only then exercise of determining ALP should be completed - AT
Transfer pricing adjustment - TPO made an adjustment taking in to consideration the OP/OC for AE segment at 23% [26%(-)3%,an allowance for delay in receivables and after sales services and other efforts made under the non-AE business] - some reasonable comparables should be selected after considering the FAR analysis of such comparable and only then exercise of determining ALP should be completed - AT
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