2013 (8) TMI 1076

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..... nst the common order passed by the CIT(A), Kozhikode dated 20-03-2013 and pertain to assessment years 2007-08 and 2008-09. Since common issue arises for consideration in both the appeals, we heard them together and dispose of the same by this common order. 2. The only issue arises for consideration is addition of deemed dividend u/ 2(22)(e) of the Act. 3. Shri K.K. John, the ld.DR submitted .....

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..... cial shareholders of KTC Automobiles Pvt Ltd are partners in the assessee firm. Therefore, when the money was received by the firm on behalf o the partners, the deemed dividend has to be assessed only in the hands of the partners and not in the hands of the firm. This is for the simple reason that the firm is not a shareholder in the lending company. Since the partners are shareholders and funds w .....

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