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2019 (3) TMI 1137 - BOMBAY HIGH COURTDeemed dividend u/s 2(22))e) - repayment of loan or advance by the Company - HELD THAT:- CIT(A) and the Tribunal accepted the Assessee's contention that, the amount in question did not represent a loan or advance given to the Assessee by the Company but the same was merely in the nature of repayment of the past loan by the Assesssee to the Company. The CIT(A) in the first as well as in subsequent order after remand, has referred to the documents on record at considerable length and come to the factual finding that, upon the perusal of the accounts between the Assessee and the Company, what can be gathered is that, the sum of ₹ 4.07 Crores was repayment of the loan by the Company. Tribunal confirmed these findings and dismissed the Revenue's appeals. The entire issue is thus based on appreciation of facts on record. Therefore, no question of law arises.
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