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...
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
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