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...
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
ITAT remanded the transfer-pricing issues to the file of the AO/TPO for fresh benchmarking of international transactions, holding that key contentions raised by the assessee regarding pricing and comparability were raised for the first time on appeal and require reconsideration; grounds 2-8 were partly allowed for statistical purposes. The Tribunal directed the AO/TPO to permit interest disallowance under the proviso to s.36(1) to be treated as revenue expenditure in favour of the assessee. The Tribunal also held that contested advertisement expenditure is revenue in nature and allowed the corresponding ground of appeal.
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