Strict Interpretation of Section 2(22)(e) Prevails: Investment Not Deemed Dividend, Tax Addition Rejected

ITAT ruled in favor of the assessee, rejecting deemed dividend assessment under section 2(22)(e). The tribunal distinguished between investment and advance, emphasizing strict interpretation of tax provisions. Factual findings by CIT(A) remained unchallenged by revenue, and no ingredients of deemed dividend were satisfied. The tribunal found no loan or advance received by the assessee from the referenced entities. Consequently, the assessing officer's addition was set aside, and the assessee's appeal was allowed, affirming the legal principle that fictional tax provisions must be construed narrowly. .....

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