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2005 (4) TMI 10 - AAR - Income TaxApplicant is an Indian company and is a tax resident of India. It is engaged in the manufacture and trading of threads. It proposes to advance interest bearing loan to M/s. Coats Finance Co. Ltd., (CFL), a company incorporated in England and Wales (UK) and a tax resident of the UK – held that proposed loan to be given by applicant to Coats Finance Co. Ltd. (CFL) would not be "deemed dividend" u/s 2(22)(e) of the Income-tax Act, 1961 to the extent of "accumulated profits"
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