Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
ITAT adjudicated a tax dispute involving loan disbursement and potential deemed dividend under Section 2(22)(e). The tribunal found that the loan was sanctioned jointly with co-applicants and disbursed to a company, which subsequently transferred funds to the assessee. Critically, the tribunal determined the transaction did not constitute a deemed dividend because the funds originated from a bank loan, not accumulated profits. The addition made based on Internal Audit Party observations was deemed unsustainable, as no incriminating material was discovered during search proceedings. Consequently, the tribunal allowed the assessee's appeal, effectively quashing the tax assessment and rejecting the proposed addition under the specified provision.
ITAT adjudicated a tax dispute involving loan disbursement and potential deemed dividend under Section 2(22)(e). The tribunal found that the loan was sanctioned jointly with co-applicants and disbursed to a company, which subsequently transferred funds to the assessee. Critically, the tribunal determined the transaction did not constitute a deemed dividend because the funds originated from a bank loan, not accumulated profits. The addition made based on Internal Audit Party observations was deemed unsustainable, as no incriminating material was discovered during search proceedings. Consequently, the tribunal allowed the assessee's appeal, effectively quashing the tax assessment and rejecting the proposed addition under the specified provision.
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