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...
TP adjustment - scope of Mutually Agreed Procedure (MAP) for determining the tax between India & USA - once CBDT in the later year agreed that transfer pricing consideration in relation to US based transactions can be safely adopted for the purpose of the assessee's non-US based transactions then it would be wholly inappropriate to allow the revenue to argue to the contrary
TP adjustment - scope of Mutually Agreed Procedure (MAP) for determining the tax between India & USA - once CBDT in the later year agreed that transfer pricing consideration in relation to US based transactions can be safely adopted for the purpose of the assessee's non-US based transactions then it would be wholly inappropriate to allow the revenue to argue to the contrary
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