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2017 (11) TMI 322 - AT - Income TaxAdditions for deemed dividend u/s 2(22)(e) - Held that:- In Circular No.19/2017, paragraph 3, the CBDT has also held that trade advances, which are in the nature of commercial transactions would not fall within the ambit of the word ‘advance’ in Section 2(22)(e) of the Act. The addition u/s 2(22)(e) is made in the case of an assessee who is an individual. Admittedly, no advance or borrowed money is received by the assessee from the concerns in which the assessee is a shareholder. There is a transaction of advancing of money by M/s Superior Films (P) Ltd. to the group concerns in the normal course of business. In view of the above as well as CBDT’s Circular No.19/2017, Section 2(22)(e) is not applicable in the facts of the case under appeal before us. - Decided in favour of assessee.
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