Derivative abetment liability fails when correctly declared imported components establish no underlying improper importation by the principal importer...
Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
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.
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