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2019 (12) TMI 609 - AT - Income TaxDeemed dividend u/s 2(22)(e) - CIT-A deleted the addition - HELD THAT:- CIT-A has allowed the appeal of the assessee and deleted the addition in dispute by holding that the amount cannot be taxed as deemed dividend u/s. 2(22)(e) in the hands of the assessee company who was not the share holder of the lender company. CIT(A) further observed that in the assessment year 2010-11 the deemed dividend in dispute was received by the assessee company from M/s Puran Associates Pvt. Ltd. would be taxed in the hands of Sh. Ashok Chand Burman and Mrs. Minnie Burman who are shareholders holding substantial interest in M/s Puran Associates Pvt. Ltd. who holds a substantial interest in the assessee company and are the share holders in both the companies. CIT(A) has rightly directed the Assessing Officer to take necessary action to tax the amount in dispute in the hands of Sh. Ashok Chand Burman and Mrs. Minnie Burman. No interference is called for in the well reasoned order dated 27.05.2015 passed by the Ld. First Appellate Authority, therefore, we uphold the action of the Ld. CIT(A) on the issue in dispute and reject the ground raised by the Revenue.
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