Income Tax : Courts have held that reopening an assessment on identical facts under a different deeming provision is invalid. The key takeaway ...
Income Tax : Learn about deemed dividends under Section 2(22) of the Income-tax Act, 1961, its implications, and key judicial precedents relate...
Income Tax : Gain insights on Deemed Dividends under the Income Tax Act: Understand taxability, TDS applicability, and key exemptions for optim...
CA, CS, CMA : Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover i...
Income Tax : The dividend income received by non-resident individuals, including Foreign Portfolio Investors (FPIs) and Non-Resident Indian cit...
Income Tax : The issue was addition of deemed dividend under search assessment. The tribunal held that without incriminating material, addition...
Income Tax : ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling cl...
Income Tax : The issue was whether incorrect tax treatment amounts to concealment. The Tribunal held that mere wrong classification in books do...
Income Tax : The ITAT reaffirmed that Section 2(22)(e) cannot extend the definition of shareholder to a concern receiving the loan. The deemed ...
Income Tax : ITAT Delhi held that Section 2(22)(e) cannot apply where the assessee held less than 10% shareholding in the lending company. As s...
Income Tax : Section 2(22) clause (e) of the Income Tax Act, 1961 (the Act) provides that dividend includes any payment by a company, not being...
Madras High Court halts Rs. 9403.09 Cr Income Tax demand against Cognizant Technology Solutions India. Detailed analysis and implications of the order.
Explore ITAT Delhi’s ruling limiting deemed dividend addition to shareholders. Details on assessment years 2013-14, 2014-15, and 2015-16. Full text analysis.
ITAT Chennai held that addition u/s. 2(22)(e) towards amount received by shareholder company treating debit balance as deemed dividend unsustainable as debit balance was only because of an inadvertent error and the same was squared off within short period.
ITAT Ahmedabad held that addition of amount received as advances as deemed dividend in terms of section 2(22)(e) of the Income Tax Act unsustainable as assessee firm is neither registered shareholder nor beneficial shareholder. Concluded that deemed dividend is taxable only in the hands of the shareholder.
ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act not leviable since there is no concealment of particulars of income by the assessee.
ITAT Bangalore held that the share premium received by the company is in excess of fair market value of the share, the addition thus made u/s. 56(2)(viib) of the Income Tax Act is found to be just and proper.
ITAT Kolkata held that there is no finding that interest bearing funds have been applied for purpose of making investment. Further, on account of sufficient availability of interest free funds, interest disallowance under rule 8D(2)(ii) unjustified.
ITAT Chennai held that transaction of purchase of own shares by the appellant company is distribution of accumulated profits within the meaning of section 2(22) of the Income Tax Act, 1961. Accordingly, it is treated as dividend u/s. 2(22)(a)/2(22)(d) read with section 115-O of the Act.
The dividend income received by non-resident individuals, including Foreign Portfolio Investors (FPIs) and Non-Resident Indian citizens (NRIs), is taxable at a rate of 20% without any deductions under the Income-tax Act.
ITAT Delhi held that the amounts advanced for business transaction between the parties would not fall within the definition of deemed dividend under section 2(22)(e) of the Act.
