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 accrued in India or not - Dependent Agent - PE in India or not? - The Tribunal upheld the assessee's argument that its operations did not constitute a business connection or PE in India, as core activities were conducted outside the country. Previous Tribunal decisions supported the conclusion that the Indian branch's activities were preparatory/auxiliary and did not constitute a PE. The Tribunal directed the assessing officer to allow TDS credit as claimed and dismissed penalty proceedings and interest levy.
Income accrued in India or not - Dependent Agent - PE in India or not? - The Tribunal upheld the assessee's argument that its operations did not constitute a business connection or PE in India, as core activities were conducted outside the country. Previous Tribunal decisions supported the conclusion that the Indian branch's activities were preparatory/auxiliary and did not constitute a PE. The Tribunal directed the assessing officer to allow TDS credit as claimed and dismissed penalty proceedings and interest levy.
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