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...
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
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