Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Section 2(22)(e) deems certain loans or advances to be dividends but enlarges only the meaning of dividend, not shareholder status. Its Explanation 3 defines "concern" as a HUF, firm, association of persons, body of individuals or company, and does not include a public Trust. A loan or advance from a private company to a public Trust therefore ordinarily cannot be treated as deemed dividend merely because the managing trustee holds substantial shares in the lender. The position may differ if the Trust is itself a qualifying shareholder or acts as a conduit for the trustee's individual benefit. On the stated facts, the reopening order and notices were quashed.
Section 2(22)(e) deems certain loans or advances to be dividends but enlarges only the meaning of dividend, not shareholder status. Its Explanation 3 defines "concern" as a HUF, firm, association of persons, body of individuals or company, and does not include a public Trust. A loan or advance from a private company to a public Trust therefore ordinarily cannot be treated as deemed dividend merely because the managing trustee holds substantial shares in the lender. The position may differ if the Trust is itself a qualifying shareholder or acts as a conduit for the trustee's individual benefit. On the stated facts, the reopening order and notices were quashed.
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