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...
TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively fulfill (1) need test, (2) rendition test, (3) benefit test, (4) duplicative test and (5) shareholders activity test. On looking at the services it is apparent that some of the services have overlapped these tests. It cannot be said that even the IT network services should have a nil arm's-length price. - AO/TPO is directed to verify the claim of the assessee - AT
TP Adjustment - determination of Arm's Length Price - intra group services transactions as Cross-charges - Documents submitted by the assessee do not conclusively fulfill (1) need test, (2) rendition test, (3) benefit test, (4) duplicative test and (5) shareholders activity test. On looking at the services it is apparent that some of the services have overlapped these tests. It cannot be said that even the IT network services should have a nil arm's-length price. - AO/TPO is directed to verify the claim of the assessee - AT
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