Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Deemed dividend u/s 2(22)(e) - taxability in hand of concern - proper reading of Section 2(22)(e) can only lead to one conclusion that the amount which is borrowed by the Assessee from VCIPL, in which Verizon Singapore holds more than 10% of voting power can if it all, be taxed only as deemed dividend in the hands of Verizon Singapore and not the Assessee - no substantial question of law arises
Deemed dividend u/s 2(22)(e) - taxability in hand of concern - proper reading of Section 2(22)(e) can only lead to one conclusion that the amount which is borrowed by the Assessee from VCIPL, in which Verizon Singapore holds more than 10% of voting power can if it all, be taxed only as deemed dividend in the hands of Verizon Singapore and not the Assessee - no substantial question of law arises
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