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2013 (10) TMI 476 - AT - Income TaxDeemed dividend u/s 2(22)(e) - nature of advances received against the bills raised for the services rendered - accumulated profit - Held that:- Amounts received by the assessee from M/s Ushodaya Enterprises P. Ltd. cannot be treated as deemed dividend under section 2(22)(e) of the Act - CIT(A) has elaborately and exhaustively dealt with the issue by examining all the relevant facts and materials and thereafter has come to the conclusion that the amounts received by the assessee from M/s Ushodaya Enterprises is in regular course of trade, hence, outside the purview of section 2(22)(e) of the Act - Assessing Officer neither in course of the assessment proceeding nor in his remand report has brought any materials to establish the fact that the amount received was not in regular course of trade but in the nature of loan and advance as envisaged u/s 2(22)(e) of the Act - No reason to interfere with the order passed by the CIT(A) in all the assessment years under consideration and uphold the same – Decided against the Revenue.
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