Interpretation -Natural Justice – Audi Alteram Partem – Right of hearing – Cross -Examination – Matter remanded to first Appellate Authority .[IT Act , 1961 , S. 226 (3) ]
Interpretation -Natural Justice – Audi Alteram Partem – Right of hearing – Cross -Examination – Matter remanded to first Appellate Authority .[IT Act , 1961 , S. 226 (3) ]
S. 2(22)(e):Deemed dividend – Loans and advances to subsidiary – Not established the business purposes – Addition as deemed dividend is held to be valid – Reassessment is also held to be valid [ S. 147 , 148 ]
S. 2(22)(e):Deemed dividend –Redeemable debenture – Addition cannot be made as deemed dividend – Advance for purchase of machinery – In the course of business addition cannot be made as deemed dividend – Intercorporate deposit – Repaid before end of relevant year – Addition as deemed dividend is held to be justified
S. 2(22)(e):Deemed dividend – Business transaction – Common directors – Advance in the course of business as commercial transactions – Addition cannot be made as deemed dividend
S. 2(22)(e):Deemed dividend – Share holder – Transferred share holding on borrower company to lender company before advance of loan – Addition cannot be made as deemed dividend .
S. 2(22)(e):Deemed dividend – Allotment of shares- Debited value of shares in the ledger account – Addition of debit balance as deemed dividend is held to be not be not justified .
S. 2(1A) : Agricultural income – Rubber manufacturer – Sale of rubber trees and timber cannot be brought to tax under rule 7A [ R.7A ]
S.148: Reassessment — Notice -Principal Officer- Notice issued in the name of Principal officer was quashed [ S.2(35(b) , 147 , Art . 226 ]
S. 2(22)(e):Deemed dividend – Amount received from subsidiary company as advance for providing corporate guarantee- Addition cannot be made as deemed dividend .
S. 2(22)(e):Deemed dividend – Director – No evidence to prove that the advance was in respect of sale of land – Addition as deemed dividend is held to be justified .