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...
Fees for technical services - made available or not - The contention that the technology is not made available to ONGC is incorrect as the agreement not only contemplates participation but also training and collaborative research between the personnel of the non-resident and ONGC - Taxable in India as per India-Canada DTAA - AT
Fees for technical services - made available or not - The contention that the technology is not made available to ONGC is incorrect as the agreement not only contemplates participation but also training and collaborative research between the personnel of the non-resident and ONGC - Taxable in India as per India-Canada DTAA - AT
Note: It is a system-generated summary and is for quick reference only.