Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
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Deemed dividend u/s 2(22)(e) - The Tribunal emphasized that loans and advances received in the ordinary course of business, which involve payment of interest, do not fall within the deeming provisions of Section 2(22)(e) of the Income Tax Act. This principle acknowledges that not all loans or advances from a company to its shareholders should automatically be considered as deemed dividends under the Act, especially when they carry characteristics of commercial transactions, such as the charge of interest. - AT
Deemed dividend u/s 2(22)(e) - The Tribunal emphasized that loans and advances received in the ordinary course of business, which involve payment of interest, do not fall within the deeming provisions of Section 2(22)(e) of the Income Tax Act. This principle acknowledges that not all loans or advances from a company to its shareholders should automatically be considered as deemed dividends under the Act, especially when they carry characteristics of commercial transactions, such as the charge of interest. - AT
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