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...
Most Favoured Nation (MFN) - rate of taxation at source on dividends, interest, royalties or fees for technical services (hereafter ‘FTS’) - bilateral treaties in question are between India and Netherlands, France, and Switzerland, respectively - Upon India entering into a treaty or protocol does not result in its automatic enforceability in courts and tribunals; the provisions of such treaties and protocols do not therefore, confer rights upon parties, till such time, as appropriate notifications are issued, in terms of Section 90(1). - SC
Most Favoured Nation (MFN) - rate of taxation at source on dividends, interest, royalties or fees for technical services (hereafter ‘FTS’) - bilateral treaties in question are between India and Netherlands, France, and Switzerland, respectively - Upon India entering into a treaty or protocol does not result in its automatic enforceability in courts and tribunals; the provisions of such treaties and protocols do not therefore, confer rights upon parties, till such time, as appropriate notifications are issued, in terms of Section 90(1). - SC
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