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2019 (1) TMI 798 - HC - Income TaxDeemed dividend u/s 2(22)(e) - assessee was found having received amounts/loans from and has paid various amounts to its group Concern - Keyman Insurance policy - Held that:- Whether an assessee who is neither a registered nor beneficial share holder in relative concerns would be governed by Section 2(22)(e) of 1961 Act, is no more res integra and is settled at rest by Division Bench of Delhi High Court in Commissioner of Income Tax Vs. Ankitech Pvt. Ltd. [2011 (5) TMI 325 - DELHI HIGH COURT] which has been affirmed by the Supreme Court in C.I.T., Delhi-II vs. Madhur Housing and Development Company [2017 (10) TMI 1279 - SUPREME COURT OF INDIA]. The deletion made on account of deemed dividend cannot be faulted with. Addition of expenditure towards Keyman Insurance policy premium of the assessee Director, is an allowable expenses in view of the Circular by the CBDT No.38/2016, dated 22/11/2016. As we are not commended to any cogent material as would nullify the effect of the said circular no interference is caused in respect of said finding of facts and law. We are of the considered opinion that no substantial question of law arises for consideration as would warrant any indulgence.
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