Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4827 
Join Channel 
