Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Administrative fraud classification suspension does not halt independent criminal investigation or warrant-based searches into alleged economic offenc...
TDS u/s 194A - TDS on deemed dividend - loan advanced by the assessee company to the other group companies - Even if, the appellant company hold 100% shares in these companies the deemed dividend would arise when these companies give loans to the appellant holding company and not other way around when holding company gives loan to subsidiary company. Thus, we find the observation made hereinabove by the ITO(TDS) is not on the correct proposition of law. - Law does not expect the payer company to deduct TDS when the payment is made to a non-shareholder. - AT
TDS u/s 194A - TDS on deemed dividend - loan advanced by the assessee company to the other group companies - Even if, the appellant company hold 100% shares in these companies the deemed dividend would arise when these companies give loans to the appellant holding company and not other way around when holding company gives loan to subsidiary company. Thus, we find the observation made hereinabove by the ITO(TDS) is not on the correct proposition of law. - Law does not expect the payer company to deduct TDS when the payment is made to a non-shareholder. - AT
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