Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC upheld the application of deemed dividend provisions under Section 2(22)(e) where the advance granted by the company to the shareholder was not utilized for executing any business transaction. The court emphasized that exclusion from deemed dividend treatment requires proof that the advance was actually used for business purposes, not merely given for such purposes. The Assessee's admission that the advance was used to pay Income-tax under KVSS, rather than for job work, confirmed the advance's classification as deemed dividend. Repayment within the same financial year or maintenance of running accounts and ongoing business transactions did not negate this conclusion. Concurrent factual findings across multiple orders were affirmed, and the HC declined to interfere under appellate jurisdiction, ruling in favor of the Revenue.
The HC upheld the application of deemed dividend provisions under Section 2(22)(e) where the advance granted by the company to the shareholder was not utilized for executing any business transaction. The court emphasized that exclusion from deemed dividend treatment requires proof that the advance was actually used for business purposes, not merely given for such purposes. The Assessee's admission that the advance was used to pay Income-tax under KVSS, rather than for job work, confirmed the advance's classification as deemed dividend. Repayment within the same financial year or maintenance of running accounts and ongoing business transactions did not negate this conclusion. Concurrent factual findings across multiple orders were affirmed, and the HC declined to interfere under appellate jurisdiction, ruling in favor of the Revenue.
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