Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (12) TMI 1060 - AT - Income TaxDeemed dividend u/s. 2(22)(e) - as per AO common directors in both the assessee company and MPPL from whom assessee borrowed sum of ₹ 4 crores - plea of the assessee that it was not a shareholder in MPPL - Held that:- Since the Assessee in the present case is not a shareholder in the lender company, we are of the view that the action of the revenue authorities in bring to tax a sum of ₹ 4 Crores as deemed dividend u/s.2(22)(e) of the Act cannot be sustained and the said addition is directed to be deleted.- Decided in favour of assessee. Disallowance u/s. 14A - as disallowance is concerned, the same is only with regard to disallowance of ‘other expenses’ under Rule 8D(2)(iii) - Held that:- The argument advanced on this issue are general and vague. The computation has been done by the AO in accordance with the provisions of relevant Rule. No case has been made out by the assessee as to why the action of the revenue authorities in this regard are not correct. Hence this issue is decided against the assessee.
|