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2023 (5) TMI 1053 - AT - Income TaxDeemed dividend addition u/s 2(22)(e) - correctness of the CIT(A)'s action reversing the assessment findings making sec.2(22)(e) addition - assessee’s stand throughout is that the impugned sum represents intercorporate deposits bearing interest than loans/advances covered under the deeming fiction of dividends u/s.2(22)(e) - HELD THAT:- This tribunal’s learned coordinate bench in [2020 (2) TMI 616 - ITAT PUNE] has already reversed the CIT(A)'s identical action deleting the similar addition of deemed dividends representing intercorporate deposits. This tribunal’s yet another coordinate bench’s order in Revenue’s appeal [2022 (8) TMI 1382 - ITAT PUNE] has also adopted judicial consistency for accepting the Revenue’s very stand as well. Faced with the situation, we hereby adopt the above detailed reasoning mutantis mutandis to restore the impugned deemed dividend addition made by the AO in his assessment - This Revenue’s appeal succeeds.
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