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2021 (3) TMI 424 - AT - Income TaxDeemed dividend addition u/s 2(22)(e) - Amount of loans to the extent of the reserves and surplus available with M/s. Shirdi Chemicals Pvt. Ltd., falls within the ambit of provisions of section 2(22)(e) of the Act and, hence, liable to be taxed in the hands of the assessee under the head “Income From Other Sources " - HELD THAT:- The issue on applicability of provisions of section 2(22)(e) of the Act is squarely covered in favour of the assessee by the decision of the Co–ordinate Bench of the Tribunal in assessee’s own case in preceding assessment year 2019–10, 2010–11, 2011–12, 2012–13 and 2013–14 wherein the Bench in Revenue’s appeal declined to interfere with the order of the first appellate authority and upheld the same. Consequently, we do not find any infirmity in the order passed by the learned Commissioner (Appeals) by allowing the claim of the assessee. Revenue’s appeal is dismissed.
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