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...
Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for the assessee and are having their independent status - Services provided to the assessee by them are in the ordinary course of their business. - They cannot be considered as dependent agent so as to constitute a PE - assessee does not have a PE in India even under Article-5(5) of the Tax Treaty - AT
Income accrued in India - Permanent Establishment (PE) in India under Article–5 of the India–Mauritius Tax Treaty - The two companies were not exclusively working for the assessee and are having their independent status - Services provided to the assessee by them are in the ordinary course of their business. - They cannot be considered as dependent agent so as to constitute a PE - assessee does not have a PE in India even under Article-5(5) of the Tax Treaty - AT
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