Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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