Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Deemed dividend u/s 2(22)(e) - Substantial interest in lending company - common shareholder - The definition of shareholder is not enlarged by any fiction. - under no circumstances the assessee could be treated as shareholder, member receiving dividend. Hence, the assessment of this loan received by assessee cannot be treated as deemed dividend u/s.2(22)(e) of the Act. Hence, we delete the addition and allow this issue of assessee’s appeal. - AT
Deemed dividend u/s 2(22)(e) - Substantial interest in lending company - common shareholder - The definition of shareholder is not enlarged by any fiction. - under no circumstances the assessee could be treated as shareholder, member receiving dividend. Hence, the assessment of this loan received by assessee cannot be treated as deemed dividend u/s.2(22)(e) of the Act. Hence, we delete the addition and allow this issue of assessee’s appeal. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
