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...
Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services for inspection/optimization/erection/commissioning repair in India to other parties - AO/DRP is not justified in holding that assessee has used the premises of its associate company in India for rendering services to its clients. - AT
Income taxable in India - Existence of Permanent establishment (PE) - royalty/fee for technical services (FTS) - India-Germany DTAA - income from supervision services for inspection/optimization/erection/commissioning repair in India to other parties - AO/DRP is not justified in holding that assessee has used the premises of its associate company in India for rendering services to its clients. - AT
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