9911796707
TMI Blog2018 (10) TMI 244X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s Cargill Inc USA. The respondent-assessee is a two step down subsidiary of M/s Cargill Ink USA. The step up subsidiary(ies) of M/s Cargill Global Trading India Private Limited and M/s Cargill India Private Limited are different and not common. It is not possible to accept the contention that the respondent-assessee should be treated as a shareholder or beneficial owner of the shares in M/s Carg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Exemption allowed subject to all just exceptions. ITA 651/2018 Contention of the Revenue is that loan given by M/s Cargill Global Trading India Private Limited to the respondent-assessee namely M/s Cargill India Private Limited should be treated as deemed dividend under Section 2(22)(e) of the Income Tax Act,1961 is misconceived. 2. It is an accepted and admitted position that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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