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TMI Blog2020 (1) TMI 1513X X X X Extracts X X X X X X X X Extracts X X X X ..... merit in Revenue s stand invoking section 2(22)(e) deemed deduction of dividend under challenge. The fact remains that although the company hereinabove has paid for purchasing land(s) in the two assessees/directors names having 16% shares, the said lands form part of company s balance-sheet only as its assets than that of these two assessees. The said company s resolution(s) to this effect also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Sr. D.R., ORDER These two assessee s appeals for same assessment year 2015-16 arise against the learned Commissioner of Income Tax (Appeals)-11, Kolkata s separate orders; both dated 31.07.2019, passed in case Nos. CIT(A),Kolkata-11/10193/2017-18 and No. CIT(A),Kolkata11/10199/2017-18, upholding the Assessing Officer s identical action making section 2(22)(e) deemed dividend addition(s) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he fact that the above stated company had purchased land(s) in their names and got them registered as their personal holdings. This made the Assessing Officer to treat the sums involved in land transaction as deemed dividend income as upheld in the identical lower authorities discussion. 3. Both parties reiterated their respective stands during the course of hearing. Smt. Biswas strongly suppor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nds only. I find no substance in the instant last argument as well as the land in question purchased in these two directors names cannot be taken as a payment per se as well. I, therefore, direct the Assessing Officer to delete the impugned addition(s) made in these two assessees cases. No other argument has been raised during the course of hearing. 4. In the result, these assessees appea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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