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) - 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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