Saturday, March 14, 2015

Section 2(22) - Deemed dividend (Loans and advances)

The High Court of Delhi has held that merely because shares were issued belatedly in subsequent year, share application money cannot be treated as loan or deposits or advance for invoking provisions of section 2(22)(e).Section 195 could not be invoked in respect of payment by assessee of commission on export sale made to a US company which had no permanent establishment in India.

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