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2012 (6) TMI 235 - AT - Income TaxDeemed dividend - Whether loans obtained by the assessee from its subsidiaries were in the nature of deemed dividends as per section 2(22)(e) of the Income-tax Act – assessee company had received loan amounts from different subsidiaries and those borrowed funds were in turn advanced to other subsidiaries – Held that:- The assessee company has not availed any benefit out of those loans availed from its subsidiaries. The assessee company had not retained those loan funds for its own activities. All the loan amounts have been redistributed to subsidiaries. These are normal business transactions carried out by any holding company. Where regular business transactions are carried on by an assessee in its ordinary course of business in the above manner, they cannot be treated as deemed dividend for the purpose of section 2(22)(e) of the Act.
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