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 deemed to accrue or arise in India - existence or otherwise of a Permanent Establishment (PE) in India - In fact, even at the stage of Tribunal, no contrary material has been brought on record by the Revenue to rebut the claim of the assessee that no PE existed in these years. - No profit shall be attributable - AT
Income deemed to accrue or arise in India - existence or otherwise of a Permanent Establishment (PE) in India - In fact, even at the stage of Tribunal, no contrary material has been brought on record by the Revenue to rebut the claim of the assessee that no PE existed in these years. - No profit shall be attributable - AT
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