Court Rules Transactions Not Deemed Dividends u/s 2(22)(e) Due to Business Purpose Evidence and Running Accounts.

Addition u/s 2(22)(e) - deemed dividend - What is required to be seen is whether CAPL has advanced moneys as pure loan amounts or for business purposes. The agreements produced by the assessee before Ld CIT(A), which were also confronted with the AO, would prove that the transactions entered between the parties are business transactions. The Ld A.R also submitted that both the companies are maintaining accounts as running accounts only and real estate investment activity was agreed to be a continuous activity. Hence the question of making one to one reconciliation, as contended by Ld DR. would not arise in these types of transactions. - additions made u/s 2(22)(e) deleted - AT .....

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