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...
Taxability of receipts on hire of vessel on a time charter basis - Royalty receipts u/s 9(1)(vi) - Addition on the ground that Charter has option of making structural alterations to the vessel and therefore, the charterer has specific control upon the vessel for its business activities. - ITAT dismissed the argument, as the clause also stated that the vessel would be returned to its original condition at the charterer's expense and the repairs could also be undertaken by the assessee. Therefore, the vessel was under the exclusive control and command of the assessee throughout the operation, navigation, and management. - AT
Taxability of receipts on hire of vessel on a time charter basis - Royalty receipts u/s 9(1)(vi) - Addition on the ground that Charter has option of making structural alterations to the vessel and therefore, the charterer has specific control upon the vessel for its business activities. - ITAT dismissed the argument, as the clause also stated that the vessel would be returned to its original condition at the charterer's expense and the repairs could also be undertaken by the assessee. Therefore, the vessel was under the exclusive control and command of the assessee throughout the operation, navigation, and management. - AT
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