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2021 (12) TMI 397 - AT - Income TaxDeemed dividend addition u/s 2(22)(e) - Whether the impugned transaction is in the nature of business transaction and not in the nature of loan or advances? - HELD THAT:- After perusing the judgments of Rameshwarlal Sanwarmal [1979 (12) TMI 1 - SUPREME COURT], CIT Vs. Impact Containers (P.) Ltd. [2014 (9) TMI 88 - BOMBAY HIGH COURT] and CIT Vs. Jignesh P. Shah [2015 (1) TMI 1165 - BOMBAY HIGH COURT] and CIT Vs. Ankitech Pvt. Ltd. [2011 (5) TMI 325 - DELHI HIGH COURT] and after giving due credence to the circular of the CBDT and looking into the facts of the instant case, where it can be held that the transaction is a commercial transaction and hence the provisions of Section 2(22)(e) are not attracted - Decided in favour of assessee.
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