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2018 (9) TMI 1747 - AT - Income TaxDeemed dividend addition u/s 2(22)(e) - Held that:- The company had advanced loan directly to the shareholder for purchase of capital asset [land: to comply with certain land transfer restrictions] to be used by the company. The advance was not for the personal benefit of the shareholder. So section 2(22)(e) was not applicable. The registry has informed that Revenue has not preferred any appeal in assessment year 2010-11 against the above extracted CIT(A)’s order followed in the impugned assessment year. The instant issue has attained finality therefore in taxpayer’s favour since the Revenue has itself accepted correctness of the CIT(A)’s order deleting the very addition in earlier assessment year. We thus reject its sole substantive grievance as well as main appeal. - Decided against revenue
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