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 India - taxability of receipts from consultancy services and reimbursement of expenses - characterizing receipts as Fee for Included Services (“FIS”) under Article 12(4)(b) of India - Revenue has not brought on record any materials to establish the fulfillment of make available condition of Article 12(4)(b) of India – USA DTAA. - AT
Income taxable India - taxability of receipts from consultancy services and reimbursement of expenses - characterizing receipts as Fee for Included Services (“FIS”) under Article 12(4)(b) of India - Revenue has not brought on record any materials to establish the fulfillment of make available condition of Article 12(4)(b) of India – USA DTAA. - AT
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