Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
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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