Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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