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2016 (5) TMI 722 - AT - Income TaxDeemed dividend addition u/s 2(22)(e) - Held that:- Though assessee claims that she had given her personal property to the company to be used as a collateral security for the purpose of borrowings from banks and financial institutions failed to furnish any relevant proofs in support of her arguments. We further noticed that in the present case on hand, the agreement entered by the assessee with the company gives rise to so many unanswered questions. Therefore, we hold that the claim of the assessee that she had entered into a sale agreement with the company towards sale of property is not supported by any valid evidence and hence, the amount received from the company attracts deeming provisions u/s 2(22)(e) of the Act. Therefore, in our opinion, the assessee is trying to circumvent the alleged loan and advances by furnishing an unregistered sale agreement, which was later not acted upon by both the parties even now. Hence, we hold that the A.O. is right in treating the loan received by the assesse as deemed dividend under the provisions of section 2(22)(e) of the Act. The CIT(A) has considered the issue elaborately and upheld the additions made by the A.O. Therefore, we upheld the order of the CIT(A) - Decided against assessee
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