PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
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ITAT held that the payments in question do not constitute deemed dividend under section 2(22)(e) because the recipient was not a registered shareholder of the assessee-company; consequently, tax deduction at source under section 194 could not be fastened, and consequential liability under sections 201(1) and 201(1A) does not arise. Characterising the transaction as commercial lending, the Tribunal concluded that neither the deemed dividend provisions nor tax-deduction liabilities apply. The assessee's appeal was allowed and the demand under the said provisions was set aside.
ITAT held that the payments in question do not constitute deemed dividend under section 2(22)(e) because the recipient was not a registered shareholder of the assessee-company; consequently, tax deduction at source under section 194 could not be fastened, and consequential liability under sections 201(1) and 201(1A) does not arise. Characterising the transaction as commercial lending, the Tribunal concluded that neither the deemed dividend provisions nor tax-deduction liabilities apply. The assessee's appeal was allowed and the demand under the said provisions was set aside.
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