Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Addition on account of deemed dividend u/s 2(22)(e) - Admittedly, the assessee company is registered with stock exchange and fulfill all the conditions of Section 2(18) which is definition of “company in which public is substantially interested.” - AO has also failed to substantiate as to how the amount in question is in the shape of a loan/advance received by the assessee company. - Additions deleted - AT
Addition on account of deemed dividend u/s 2(22)(e) - Admittedly, the assessee company is registered with stock exchange and fulfill all the conditions of Section 2(18) which is definition of “company in which public is substantially interested.” - AO has also failed to substantiate as to how the amount in question is in the shape of a loan/advance received by the assessee company. - Additions deleted - AT
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