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    <title>2015 (1) TMI 403 - KARNATAKA HIGH COURT</title>
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    <description>Deemed dividend treatment was rejected for trade advances and loans where payments to a related concern or shareholder were made for genuine business purposes or consideration received by the company; the deeming fiction targets distributions of accumulated profits disguised as loans to avoid dividend distribution tax, not bona fide payments for business acquisition or goods. Where amounts are paid to a concern, the taxing focus is on the shareholder as the beneficial recipient rather than treating every intercompany payment automatically as deemed dividend. Consequently the advance payments were held not to be deemed dividends and relief was granted to the taxpayer.</description>
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      <title>2015 (1) TMI 403 - KARNATAKA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=255204</link>
      <description>Deemed dividend treatment was rejected for trade advances and loans where payments to a related concern or shareholder were made for genuine business purposes or consideration received by the company; the deeming fiction targets distributions of accumulated profits disguised as loans to avoid dividend distribution tax, not bona fide payments for business acquisition or goods. Where amounts are paid to a concern, the taxing focus is on the shareholder as the beneficial recipient rather than treating every intercompany payment automatically as deemed dividend. Consequently the advance payments were held not to be deemed dividends and relief was granted to the taxpayer.</description>
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