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 - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
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