Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Addition u/s 2(22)(e) - even if amount given to the assessee for making the investment in the shares of the company as said investment was required for taking the loan from the bank, it is nothing but the loan/advance in terms of section 2(22)(e) as it was the duty of the promoters as a shareholder of the said company to infuse more capital - advance is not for trading or business purposes rightly treated as deemed dividend
Addition u/s 2(22)(e) - even if amount given to the assessee for making the investment in the shares of the company as said investment was required for taking the loan from the bank, it is nothing but the loan/advance in terms of section 2(22)(e) as it was the duty of the promoters as a shareholder of the said company to infuse more capital - advance is not for trading or business purposes rightly treated as deemed dividend
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