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...
TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected
TPA - MAM selection - CUP or TNMM - if the intra AE transactions were fundamentally different in character in economic circumstances and contractual terms then these cannot be compared with the independent transactions entered into by the assessee - the availability, coverage and reliability of data necessary for application of the method - CUP rejected
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