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...
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
Tax residency certificate and Global Business License-I held by assessee investment fund incorporated in Mauritius as subsidiary of another Mauritian company. Investments made in Indian companies for over five years before transfer earning long-term capital gains. No evidence of fund flow from India. Conduit status alleged based on immediate transfer of funds after divestment, but commercial rationale established as business model to attract foreign investment. Suspicion alone insufficient to rebut statutory presumption of genuineness based on tax residency certificate. Treaty benefits rightly allowed.
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