Commercial vehicle depreciation, scientifically determined warranty provisions and exempt-income disallowances were resolved in favour of the taxpayer...
Inherited property sale proceeds require capital-gains treatment where ownership is supported by evidence, not suspicion or unverified signature doubt...
Cross-examination of retracted statements is essential where foundational evidence supports a benami allegation and documented funding explanations re...
Addition of deemed dividend u/s 2(22)(e) - proof of incriminating material found in the course of search - There is no loan or advance received by the assessee from the company. It is seen that even as per the case of the A.O. made in the assessment order, the loan or advance has been received by the assessee from the partnership firm. Therefore, as per the admitted case of the A.O., such loan or advance having not been received by the assessee from a closely held company cannot be treated as dividend u/s 2(22)(e), since the first ingredient of section 2(22)(e) itself is not met in this case. - AT
Addition of deemed dividend u/s 2(22)(e) - proof of incriminating material found in the course of search - There is no loan or advance received by the assessee from the company. It is seen that even as per the case of the A.O. made in the assessment order, the loan or advance has been received by the assessee from the partnership firm. Therefore, as per the admitted case of the A.O., such loan or advance having not been received by the assessee from a closely held company cannot be treated as dividend u/s 2(22)(e), since the first ingredient of section 2(22)(e) itself is not met in this case. - AT
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