2019 (1) TMI 1793

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..... a remand report. This finding recorded by the CIT(A) was correct, as there is no payment made by the assessee-company to its subsidiary during the previous year, relevant to the assessment year 2004-05 within the meaning of Section 2(22)(e) of the Act. Thus, we find that the first appellate authority as well as the Tribunal has considered the factual position and granted relief to the assessee. .....

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..... on of law:- Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in confirming the deletion of the entire addition of ₹ 4,16,12,082/- made by the Assessing Officer treating the said amount as deemed dividend under Section 2(22)(e) and that too by not considering a ground of appeal raised by the Revenue in the appeal? 3.Heard Mrs.R.Hem .....

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..... A) was correct, as there is no payment made by the assessee-company to its subsidiary during the previous year, relevant to the assessment year 2004-05 within the meaning of Section 2(22)(e) of the Act. 6.Thus, we find that the first appellate authority as well as the Tribunal has considered the factual position and granted relief to the assessee. Thus, we find there is no substantial question .....

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