Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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