Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
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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