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Income Tax - Highlights / Catch Notes

Home Highlights October 2016 Year 2016 This

Deemed dividends u/s. 2(22)(e) - loans and advances - The ...

Income Tax

October 27, 2016

Deemed dividends u/s. 2(22)(e) - loans and advances - The assessee blows hot and cold in the same breath. On the one hand it is claiming the impugned amount as share application money and when this story is demolished, it is taking an alternative plea on Inter-Corporate Deposits (ICD) - Additions confirmed - AT

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  1. Deemed Dividend - addition of advance salary as deemed dividend - advance was not in the nature of loan and hence cannot be treated as deemed dividend u/s 2(22)(e) - AT

  2. Deemed dividend u/s 2(22))e) - repayment of loan or advance by the Company

  3. Deemed dividend - looking at the transactions from the objects of section 2(22)(e) it cannot be said that there was diversion of dividend in the form of loans or advances.

  4. Deemed dividend - looking at the transactions from the objects of section 2(22)(e) it cannot be said that there was diversion of dividend in the form of loans or advances.

  5. Deemed dividend u/s 2(22)(e) - payments made by the company towards advances to the assessee fulfils all the characteristics of 'dividend' as envisaged in S. 2(22)(e) - AT

  6. Deemed dividend addition u/s 2(22)(e) - Since all the conditions necessary for treating the deemed dividend of the amount received in the hands of concern (which in this...

  7. Deemed dividend u/s 2(22)(e) - assessee is a major share holder in loan granting company - Advance given for purchase of property - The words “loans or advances”...

  8. Deemed dividend addition u/s.2(22) - trade advance in relation to business transaction cannot be treated as deemed dividend - AT

  9. Deemed dividend u/s 2(22)(e) - oan or advance to a non-shareholder cannot be taxed as deemed dividend in the hands of the a non shareholder - AT

  10. Deemed dividend u/s 2(22)(e) - trade advances made for the commercial transactions would not be hit by section 2(22)(e) of the Act - HC

 

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