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...
Nature of receipt under the head ‘fees for technical services’ (FTS)/Royalty - India-UK DTAA - The job of the assessee ends upon the production of the program content and the broadcasting is carried out by some other entity to which license was given by the BCCI. - the question of transfer of all or any right does not arise in the facts and circumstances of the instant case - No royalty income - AT
Nature of receipt under the head ‘fees for technical services’ (FTS)/Royalty - India-UK DTAA - The job of the assessee ends upon the production of the program content and the broadcasting is carried out by some other entity to which license was given by the BCCI. - the question of transfer of all or any right does not arise in the facts and circumstances of the instant case - No royalty income - AT
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