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2012 (7) TMI 462 - AT - Income TaxDis allowance of Business Promotion expenses - being of non-business views - Held that:- The invoice submitted by assessee reveals the purpose that the business promotion expenses were incurred as commissioning advance for value assessment of commercial plot in Noida and AO disallowed business promotion expenses only on cryptic reason stating that no details and purpose was given or offered by the assessee - the purpose of above payment as business promotion expenses was properly explained by the assessee as the fresh evidence submitted by the assessee and admitted after due procedure as provided in Rule 46A of the ITR - decided against revenue. Addition on account of deemed dividend u/s 2(22)(e) - the assessee company has taken loan from A.P. Projects Ltd. - Held that:- Shri Pankaj Bajaj was director of the assessee company and he was also a director in the lender AP Projects Private Limited during the year under consideration. In view of the exception as per sub-clause (ii) of Section 2(22)(e, the provisions of deemed dividend are not applicable as the appellant assessee company was not a shareholder in lender A.P. Projects Private Limited and Section 2(22)(e) of the Act is not applicable to a non shareholder - against revenue.
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