Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
A loan advanced by a closely held company to a shareholder can be treated as deemed dividend where the statutory conditions of section 2(22)(e) are satisfied. Applying the Supreme Court's interpretation in Smt. Tarulata Shyam, the Tribunal held that later repayment and the fact that the advance carried interest did not remove the payment from the deeming fiction. The authorities relied on by the parties were distinguished on their facts, including a money-lending exception and a specific quid pro quo absent here. The addition was therefore sustained and the appeal dismissed.
A loan advanced by a closely held company to a shareholder can be treated as deemed dividend where the statutory conditions of section 2(22)(e) are satisfied. Applying the Supreme Court's interpretation in Smt. Tarulata Shyam, the Tribunal held that later repayment and the fact that the advance carried interest did not remove the payment from the deeming fiction. The authorities relied on by the parties were distinguished on their facts, including a money-lending exception and a specific quid pro quo absent here. The addition was therefore sustained and the appeal dismissed.
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