Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Co-operative deduction eligibility excludes refund and commercial-bank interest, while qualifying co-operative investments require entity-wise verific...
Enhanced tax rate on surrendered unexplained income applies prospectively, while cash-deposit telescoping requires verification of available surrender...
ITAT upheld the applicability of deemed dividend under section 2(22)(e) where a shareholder had the requisite shareholding, a debit balance appeared in the company's books, and the company had sufficient accumulated profits; the short duration of the debit balance did not alter its character as a shareholder advance or loan. On computation, however, the Tribunal held that the net debit balance could not be determined by ignoring accrued interest on day-to-day credit balances, and the assessee had to be given a reasonable opportunity to have that adjustment considered. The matter was therefore remanded for recomputation of the amount assessable as deemed dividend.
ITAT upheld the applicability of deemed dividend under section 2(22)(e) where a shareholder had the requisite shareholding, a debit balance appeared in the company's books, and the company had sufficient accumulated profits; the short duration of the debit balance did not alter its character as a shareholder advance or loan. On computation, however, the Tribunal held that the net debit balance could not be determined by ignoring accrued interest on day-to-day credit balances, and the assessee had to be given a reasonable opportunity to have that adjustment considered. The matter was therefore remanded for recomputation of the amount assessable as deemed dividend.
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