Home Highlights March 2014 Year 2014 This

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1. Deemed dividend u/s 2(22)(e) - the expression, “accumulated profits“ means profits in the commercial sense and not assessable or taxable profits liable to tax - HC

2. Deemed dividend addition u/s 2(22)(e) - Since all the conditions necessary for treating the deemed dividend of the amount received in the hands of concern (which in this...

3. Deemed dividend u/s. 2(22)(e) - the loan given by the company only in the immediate preceding year, i.e., assessment year 2007-08, should be assessed as deemed dividend...

4. Deemed dividend u/s 2(22)(d) - Determination of accumulated profit - we are inclined to follow the accumulated loss declared by the Novateur India in their reinstated...

5. Deemed dividend addition u/s 2(22)(e) - Provisions of Section 2(22)(e) relating to loan or advance can be deemed as dividend only to the extent of accumulated profit or...

6. Deemed dividend u/s 2(22)(e) - CIT(A) was not justified in holding that the amount of capital subsidy was a part of accumulated profited to be considered as deemed...

7. Deemed dividend addition u/s 2(22)(e) - proof of accumulated profits - if the AO has accepted the income returned by the said company and not made any changes in the...

8. Deemed dividend u/s 2(22)(e) - exempted capital gains shall not enter the stream of the expression ‘accumulated profits’ and the company BKFCPL has got only negative...

9. Addition u/s 2(22)(e) - deemed dividend of income - the security premium reserve cannot be regarded as part of accumulated profits u/s 2(22)(e) and when such security...

10. Additions u/s 2(22)(e) on account of deemed dividend - Accumulated profit - As per the provision of Explanation 2, all the profits of the company up to the date of...

11. Deemed dividend u/s 2(22)(e) - accumulated profits would mean profit in the commercial sense and not assessable taxable profits - share premium account would not partake...

12. Addition of deemed dividend under Section 2(22)(e) - quantum of accumulated profits - inclusion of share premium - The share premium account cannot partake the nature of...

13. Deemed dividend addition u/s 2(22)(e) - computation of accumulated profits - it shall not include current year’s proportionate profit, since the current years profit...

14. Deemed dividend under Section 2(22)(e) - addition only qua the peak amount - Whether addition should be restricted to the peak amount of the loans given during the year?...

15. Deemed dividend - Whether loans obtained by the assessee from its subsidiaries were in the nature of deemed dividends as per section 2(22)(e) - they cannot be treated as...