DCIT vs Ramesh Kumar Pabbi
Whether a loan from a company to its substantial shareholder, where interest is paid and the transaction is commercial, constitutes deemed dividend u/s 2(22)(e) of the Income Tax Act, 1961 --- Held No. | Whether disallowance u/s 40(a)(ia) for non-deduction of TDS on testing charges payable to RITES Ltd. u/s 194J is justified --- Held No, as the payment was not for professional/technical services.
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