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...
Addition in respect of interest paid on External Commercial Borrowings (ECB), payment of guarantee fee and service fee - the assessee has been able to substantiate that the payments have been made for the purpose of assessee’s business. The TPO cannot sit in the judgment whether these expenses were necessary for conducting the business or whether any benefit has been derived from the expenditure so incurred. - AT
Addition in respect of interest paid on External Commercial Borrowings (ECB), payment of guarantee fee and service fee - the assessee has been able to substantiate that the payments have been made for the purpose of assessee’s business. The TPO cannot sit in the judgment whether these expenses were necessary for conducting the business or whether any benefit has been derived from the expenditure so incurred. - AT
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