Advance to Director for Sale of Land cannot be treated as Deemed Dividend

Jitendra Kumar Gupta Vs. ACIT (ITAT Delhi) We find that in this case assessee is a share holder of more than 10% shares in IHDP Globals (P) Ltd. and during the year, the company gave funds totaling Rs. 1,67,00,000/- to the assessee which has been added by the AO u/s. 2(22)(e) of the Act and later the Ld. CIT(A) confirmed the findings of AO. We further note that during the year the company gave Rs. 1,67,00,000/- to the assessee. In my opinion it is not in the nature of advance or loan within the meaning of section 2(22)(e) of the Act. However, it is an advance given by the company to the assess...