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Income Tax - Highlights / Catch Notes

Home Highlights July 2020 Year 2020 This

Deemed dividend u/s 2 (22)(e) - advance made by the subsidiary ...

Income Tax

July 29, 2020

Deemed dividend u/s 2 (22)(e) - advance made by the subsidiary company to the respondent/holding company - Obviously, the department would have been well aware of the fact that the amount of ₹ 3.00 Crores advanced by the subsidiary to its holding company, cannot be taxed twice. When such being the position, we are really surprised to see that the initiation of two separate proceedings for the same transaction is not appreciable. - HC

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

  6. 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

  7. Deemed dividend u/s 2(22)(e) - transactions made by the assessee and the company are for business purposes and are not deemed dividend under section 2(22)(e) - AT

  8. 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.

  9. 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.

  10. Advances taken against the supply are not covered by the provisions of Deemed dividend u/s 2(22)(e) - AT

 

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