2020 (1) TMI 1513

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... T, Sr. D.R., ORDER These two assessee's appeals for same assessment year 2015-16 arise against the learned Commissioner of Income Tax (Appeals)-11, Kolkata's separate orders; both dated 31.07.2019, passed in case Nos. CIT(A),Kolkata-11/10193/2017-18 and No. CIT(A),Kolkata11/10199/2017-18, upholding the Assessing Officer's identical action making section 2(22)(e) deemed dividend addition(s) .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... the above stated company had purchased land(s) in their names and got them registered as their personal holdings. This made the Assessing Officer to treat the sums involved in land transaction as deemed dividend income as upheld in the identical lower authorities discussion. 3. Both parties reiterated their respective stands during the course of hearing. Smt. Biswas strongly supported the CIT(A) .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... I find no substance in the instant last argument as well as the land in question purchased in these two directors names cannot be taken as a "payment" per se as well. I, therefore, direct the Assessing Officer to delete the impugned addition(s) made in these two assessees' cases. No other argument has been raised during the course of hearing. 4. In the result, these assessees appeals are allowe .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X