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    <title>Group-company timeshare week purchases and sales: treated as commercial deals, not s.2(22)(e) loans; additions and invalid assessment struck down.</title>
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    <description>Amounts received/paid between the taxpayer and group companies for purchase/sale of timeshare weeks were held to be commercial transactions, supported by consideration and indirect tax payment, and therefore not &quot;loans or advances&quot; attracting deemed dividend under s. 2(22)(e); the addition was deleted and the revenue&#039;s ground failed. Commission expenditure was allowed since the taxpayer furnished adequate particulars and there was no evidence of cash-back or off-book payments; disallowance merely for non-confirmation by parties was rejected and the revenue&#039;s ground failed. Depreciation on capitalised timeshare weeks was sustained as forming part of the building block/cost of improvement, consistently accepted in later years; the revenue&#039;s g.....</description>
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    <pubDate>Tue, 23 Dec 2025 07:59:05 +0530</pubDate>
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      <title>Group-company timeshare week purchases and sales: treated as commercial deals, not s.2(22)(e) loans; additions and invalid assessment struck down.</title>
      <link>https://www.taxtmi.com/highlights?id=95308</link>
      <description>Amounts received/paid between the taxpayer and group companies for purchase/sale of timeshare weeks were held to be commercial transactions, supported by consideration and indirect tax payment, and therefore not &quot;loans or advances&quot; attracting deemed dividend under s. 2(22)(e); the addition was deleted and the revenue&#039;s ground failed. Commission expenditure was allowed since the taxpayer furnished adequate particulars and there was no evidence of cash-back or off-book payments; disallowance merely for non-confirmation by parties was rejected and the revenue&#039;s ground failed. Depreciation on capitalised timeshare weeks was sustained as forming part of the building block/cost of improvement, consistently accepted in later years; the revenue&#039;s g.....</description>
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      <pubDate>Tue, 23 Dec 2025 07:59:05 +0530</pubDate>
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