Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights September 2023 Year 2023 This

Deemed dividend u/s 2(22)(e) - assessee has a strategic ...

Case Laws     Income Tax

September 22, 2023

Deemed dividend u/s 2(22)(e) - assessee has a strategic investment in one of the group concerns in which the assessee held 17.20% shareholding - The benefit is not individual but solely on business exigency. The deeming provision is always under the control of express provision. It is pertinent to observe that the benefit of expressed provision is covered in deeming provision or not. Considering the factual matrix, the assessee did not get any direct benefit of the payment made by GAPL and the amount was returned back to party. - Additions deleted - AT

View Source

 


 

You may also like:

  1. Deemed dividend u/s 2(22)(e) - taxability in hand of concern - proper reading of Section 2(22)(e) can only lead to one conclusion that the amount which is borrowed by...

  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) arises when an interest-free loan is provided by a company to a substantially related concern in shareholding. The issue was whether the...

  4. Deemed dividend u/s.2(22)(e) - a business transaction between two concerns, under which amount is transferred from one to another cannot be treated as dividend in the...

  5. 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...

  6. 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

  7. 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?...

  8. Deemed dividend made u/s 2(22)(e) - The alleged transactions are purely entered between the two concerns in the ordinary course of business as advance or loan for which...

  9. 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...

  10. 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...

  11. 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...

  12. Deemed dividend addition u/s.2(22)(e) - advances given to sister concern without interest - Transactions were purely out of trading transactions between the two concerns...

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

  14. Deemed dividend under sec. 2(22)(e) - Initially, the assessee has chosen to declare the deemed dividend in his hand, later come with different explanation at different...

  15. Deemed dividend u/s 2(22)(e) - payments made by the company towards advances to the assessee fulfils all the characteristics of 'dividend' as envisaged in S. 2(22)(e) - AT

 

Quick Updates:Latest Updates