Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Deemed dividend u/s 2(22)(e) - assessee company is a shareholder of lender company or not? - The ITAT held that for amounts to be considered as deemed dividends under Section 2(22)(e), specific conditions must be met, including the recipient being a shareholder of the lender company. The court found that the appellant companies were not shareholders of M/s. IG3 Infra Limited at the time of receiving the funds, hence the provisions of Section 2(22)(e) could not be applied.
Deemed dividend u/s 2(22)(e) - assessee company is a shareholder of lender company or not? - The ITAT held that for amounts to be considered as deemed dividends under Section 2(22)(e), specific conditions must be met, including the recipient being a shareholder of the lender company. The court found that the appellant companies were not shareholders of M/s. IG3 Infra Limited at the time of receiving the funds, hence the provisions of Section 2(22)(e) could not be applied.
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