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...
Additions of Income of other person u/s 60 & 63(b) - transfer of income without transfer of corresponding asset by the assessee - As is evident from records, FCDs were issued by TGSPL to Serco International SARL much prior to reduction in share capital. Since, there is no generation of income there can be no question of transfer of income to any other person. - Additions deleted - AT
Additions of Income of other person u/s 60 & 63(b) - transfer of income without transfer of corresponding asset by the assessee - As is evident from records, FCDs were issued by TGSPL to Serco International SARL much prior to reduction in share capital. Since, there is no generation of income there can be no question of transfer of income to any other person. - Additions deleted - AT
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