Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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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