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...
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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