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2016 (10) TMI 1126 - AT - Income TaxDeemed dividend addition u/s. 2(22)(e) - assessee company had 22.3% share capital of SDBPL and had also availed loan along with several financial transaction with the said company during the year - CIT-A deleted the addition - Held that:- Findings of CIT(A) shows that he has followed the findings given in A.Y. 2006-07 wherein the First Appellate Authority has followed the decision taken in the case of SDBPL, the appeal of SDBPL travelled up to the Hon’ble Jurisdictional High Court of Gujarat wherein held that as looking to large number of adjustment entries in the accounts between two entities, the amounts were not in the nature of loan or deposit, but merely adjustments, application of section 2(22)(e) of the Act would not arise. - Decided in favour of assessee.
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