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...
Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT
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