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 - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
TP Adjustment - Addition of international transaction related to the demerger - The High court identified a jurisdictional overreach by the AO, who made an adjustment beyond the scope of the TPO's determination. It was noted that the TPO's order did not explicitly dictate the inclusion of the demerged business's value in the ALP calculation, rendering the AO's addition legally unsustainable. The judgement emphasized the sanctity of procedural adherence and the delineated roles of the AO and TPO in the context of transfer pricing adjustments. - The Court set aside the impugned order and remanded the matter back to the AO.
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