Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Passenger baggage re-export requires true declaration and cannot be granted indirectly through discretionary redemption of undeclared prohibited goods...
Addition u/s 2(22)(e) - deemed dividend - interest bearing Loans - proportionate ownership of property acquired out of borrowed fund by the “company” to the extent of loan/advance lies with the assessee - CIT(A) is justified in holding that the AO is not right in bring to tax sum as a deemed dividend in the hands of the assessee. Since, We held that the provision of section 2(22)(e) of the Act have no application to the facts of the case - AT
Addition u/s 2(22)(e) - deemed dividend - interest bearing Loans - proportionate ownership of property acquired out of borrowed fund by the “company” to the extent of loan/advance lies with the assessee - CIT(A) is justified in holding that the AO is not right in bring to tax sum as a deemed dividend in the hands of the assessee. Since, We held that the provision of section 2(22)(e) of the Act have no application to the facts of the case - AT
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