Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
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Deemed dividend u/s 2(22)(e) - amount received as part of salary/remuneration paid to the assessee - The ITAT examined the statements recorded during the survey and the impounded trial balance. It noted that while the appellant claimed the amount was received as advance against remuneration, the trial balance showed the amount under the head of short term loan & advance. However, the Tribunal observed that the books of accounts were incomplete at the time of the survey, and entries made by the junior accountant were not approved by management. - The tribunal accepted the argument that the company had deducted TDS on remuneration paid. - The ITAT held that since the appellant had already accounted for the disputed amount in their income tax return and paid tax on it, there would be double taxation if the amount was treated as deemed dividend.
Deemed dividend u/s 2(22)(e) - amount received as part of salary/remuneration paid to the assessee - The ITAT examined the statements recorded during the survey and the impounded trial balance. It noted that while the appellant claimed the amount was received as advance against remuneration, the trial balance showed the amount under the head of short term loan & advance. However, the Tribunal observed that the books of accounts were incomplete at the time of the survey, and entries made by the junior accountant were not approved by management. - The tribunal accepted the argument that the company had deducted TDS on remuneration paid. - The ITAT held that since the appellant had already accounted for the disputed amount in their income tax return and paid tax on it, there would be double taxation if the amount was treated as deemed dividend.
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