Deemed Dividend U/s 2(22)(e) Largely Deleted & Sec.54 Deduction Allowed

Atul Bansal Vs ACIT (ITAT Delhi) This case involved cross-appeals against CIT(A) order where the AO treated huge advances of ₹71.08 Cr as deemed dividend u/s 2(22)(e) and disallowed deduction u/s 54. The Tribunal examined shareholding thresholds, accumulated profits, NBFC exception & factual matrix in detail. Issue 1 — Deemed Dividend u/s 2(22)(e): The AO made addition alleging loans from group companies (ABW Infrastructure Ltd., VPS Realtors Pvt. Ltd., Par Excellence Leasing & Financial Services Ltd.). CIT(A) deleted most additions after verifying shareholding & nature of rese...