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2016 (12) TMI 1852 - DELHI HIGH COURTDeemed dividend addition u/s 2(22)(e) - HELD THAT:- ITAT analysed the facts and based upon the material on record deduced firstly, that similar transactions were not treated as advances but were in respect of third parties and the explanation that they were trade credits were accepted. The ITAT, therefore, was of the view that there was no loan to the assessee in the circumstances of the case. We are of the opinion that the plain text of Section 2(22)(e) does not authorise the treatment of the amounts as a loan to a shareholder since concededly the amounts were not received by the assessee, an individual. See ANKITECH PVT LTD. & OTHERS [2011 (5) TMI 325 - DELHI HIGH COURT] - No substantial question of law arises.
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