Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
TDS u/s 195 - expenses in foreign currency - Advertisement and business promotion expenses - do not fall in the nature of technical, managerial or consultancy services - unless an amount (income) can be said to have accrued or arisen in India or deemed to have accrued or arisen in India, the provisions of section 195 is not applicable - no disallowance u/s 40(a)(i)
TDS u/s 195 - expenses in foreign currency - Advertisement and business promotion expenses - do not fall in the nature of technical, managerial or consultancy services - unless an amount (income) can be said to have accrued or arisen in India or deemed to have accrued or arisen in India, the provisions of section 195 is not applicable - no disallowance u/s 40(a)(i)
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