2016 (5) TMI 1613

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..... ion 1(b) of section 115JB - CIT(A) deleted addition made u/s 2(22)(e) and holding that the debenture redemption reserve is not a reserve within the meaning of Explanation 1(b) of section 115JB - Assessee submitted that the tax effect in this case is below 10 Lakhs and as per the CBDT Circular No. 21 of 2015, dated 10-12-2015, the present appeal is not maintainable. HELD THAT:- DR fairly co .....

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..... d the impugned order on following effective grounds:- 1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made u/s 2(22)(e) of the Act holding that the loan received by the assessee from its 100% subsidiary is not in the manner of deemed dividend though the total accumulated profit of the subsidiary during the current year is Rs. 18, .....

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..... s irrelevant because as per assessment order dated 05/03/2013 passed u/s 143(3) of the Act, the tax payable under the normal provisions of the Act is higher than the tax payable u/s 115JB of the Act. 5. The Ld. DR fairly conceded that the tax effect in department s appeal is below 10 Lakhs. We find that the issue raised in appeal does not fall under any of the exceptions specified in para 8 of .....

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