Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
Customs exemptions cover photovoltaic assembly machinery and PVF backsheets, while fully declared cleared imports may avoid confiscation and penalties...
Specific tariff classification for LCD devices overrides treatment as electricity-meter parts, defeating differential duty, extended limitation, and p...
Stayed disciplinary punishment does not establish unfitness for insolvency professional registration; reconsideration must disregard mere pendency of ...
Indirect corporate control can create related-party status, excluding financial creditors from Committee of Creditors representation, participation an...
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The ITAT held that the provisions of deemed dividend under section 2(22)(e) do not apply where the assessee, not being a beneficial or registered shareholder, received loans from sister concerns in which the holding company has substantial interest. Both limbs of the section were found inapplicable as there was no evidence of funds being transferred to the holding company. Consequently, the addition under section 2(22)(e) was deleted. Regarding the addition under section 68 for an unsecured loan from a related party, the Tribunal accepted the assessee's evidence of genuineness and creditworthiness, including group affiliations, consistent bookkeeping, confirmation, and a favorable arbitration award. The AO's observations were insufficient to disprove the transaction's bona fides. The Tribunal affirmed the genuineness without remitting the matter, ruling in favor of the assessee and directing deletion of the impugned additions.
The ITAT held that the provisions of deemed dividend under section 2(22)(e) do not apply where the assessee, not being a beneficial or registered shareholder, received loans from sister concerns in which the holding company has substantial interest. Both limbs of the section were found inapplicable as there was no evidence of funds being transferred to the holding company. Consequently, the addition under section 2(22)(e) was deleted. Regarding the addition under section 68 for an unsecured loan from a related party, the Tribunal accepted the assessee's evidence of genuineness and creditworthiness, including group affiliations, consistent bookkeeping, confirmation, and a favorable arbitration award. The AO's observations were insufficient to disprove the transaction's bona fides. The Tribunal affirmed the genuineness without remitting the matter, ruling in favor of the assessee and directing deletion of the impugned additions.
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