Revision u/s 263 by CIT - buy back of shares from its own ...

CIT Revises Assessment on Share Buyback; Deemed Dividend u/s 2(22)(d) and Taxable u/s 115-O.

April 19, 2022

Case Laws Income Tax AT

Revision u/s 263 by CIT - buy back of shares from its own holding company - deemed dividend under section 2(22)(d) - dividend distribution tax u/s 115-O - CIT has flagged a pertinent issue and fully justified as to how the assessment order was erroneous as well as prejudicial to the interest of the revenue. Upon perusal of assessment orders, we find that this issue was never delved into by Ld. AO or Ld. TPO and there was complete non-application of mind on the sated issue. - AT

View Source

← Previous Next →

Revision u/s 263 by CIT - buy back of shares from its own ...

CIT Revises Assessment on Share Buyback; Deemed Dividend u/s 2(22)(d) and Taxable u/s 115-O.

April 19, 2022

Case Laws Income Tax AT

You may also like:

Powers of CIT(A) u/s 251 - Enhancement of assessment - New source of income introduced by CIT(A) while deciding the appeal and enhancement of income - Deemed dividend...

Deemed dividend u/s. 2(22)(a)/2(22)(d) r.w.s. 115-O - purchase/ buyback of its own shares by the company - It is to be noted that as per the proviso to Sec. 2(22), only...

Deemed dividend u/s 2(22)(e) arises when an interest-free loan is provided by a company to a substantially related concern in shareholding. The issue was whether the...

Set off of deemed dividend against actual dividend paid by certain companies - dividend distribution tax as per section 115-O is in respect of dividend covered u/s...

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...

Deemed dividend addition u/s 2(22)(e) - Liability of firm or individual directors - Since the plain reading of Section 2(22)(e) of the Act makes it clear that the deemed...

Deemed dividend u/s 2(22)(e) - shares held in the name of minor children - no such benefit accrued, and hence the assessee could not be said to be the beneficial owner...

Deemed dividend u/s 2(22)(e) is not taxable in the hands of the assessee company if it is not a shareholder in the companies that extended loans. It is chargeable to tax...

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...

Deemed dividend u/s 2(22))e) - repayment of loan or advance by the Company

Deemed dividend u/s 2(22)(e) - transactions made by the assessee and the company are for business purposes and are not deemed dividend under section 2(22)(e) - AT

Addition u/s 2(22) - Deemed dividend - the amount in the nature of capital or not - dividend was declared before liquidation and dividend distribution tax was paid u/s....

Deemed dividend u/s 2(22)(e) - if the lending of money constitutes substantial part of business of the company, then the loan given by the company to its share holders...

Deemed dividend u/s.2(22)(e) - loan received by the Assessee from QNEI - the Assessee is not a shareholder of QNEI, the amount received from QNEI will not be taxable in...

Deemed dividend u/s 2(22)(e) - Substantial interest in lending company - common shareholder - The definition of shareholder is not enlarged by any fiction. - under no...

Quick Updates: