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TMI Blog2020 (10) TMI 1154X X X X Extracts X X X X X X X X Extracts X X X X ..... share holder? - to be assessed in the hands of the share holder or in the hands of the firm - share holder of the company had substantial interest in the firm - HELD THAT:- Substantial Questions of Law raised by the Revenue in the instant case was considered by this Court earlier in the case of The Commissioner of Income Tax, Chennai Vs. M/s T.Abdul Wahid Co [ 2020 (9) TMI 977 - MADRAS HIGH COURT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 260 A of the Income Tax Act, 1961 ('the Act' for brevity) is directed against the order dated 07.11.2012 passed by the Income Tax Appellate Tribunal, Madras 'D' Bench, Chennai in I.T.A.No.1753/Mds/2012 for the Assessment Year 2008- 09. The Revenue has raised the following Substantial Questions of Law for consideration: 1. Whether on the facts and in the circumstances of the case, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e and Mr.R.Vijayaraghavan, learned counsel for M/s.Subbaraya Aiyar Padmanabhan, learned counsel for the respondent. 3. It is not disputed before us that the Substantial Questions of Law raised by the Revenue in the instant case was considered by this Court earlier in the case of The Commissioner of Income Tax, Chennai Vs. M/s T.Abdul Wahid Co., in T.C.A.Nos.512 513 of 2018 dated 21.09.2020. The sa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g Counsel in the said decision that loans or advances had to be treated as dividend to the extent of accumulated profits and loan or advances may be given directly to the shareholder or it may be given for the benefit of the shareholder or on behalf of the shareholder. Therefore, it was contended that the Assessing Officer was right in treating the loan as deemed dividend under Section 2(22)(e) of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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