Current profit not to be included in accumulated profit to determine deemed dividend

Ramesh Premji Shah Vs DCIT (ITAT Mumbai) ITAT Mumbai held that while determining the amount of deemed dividend under Explanation 2 to Section 2(22)(e) of the Income Tax Act, the current profit is not to be included to be part of accumulated profit. Facts- The case of the assessee was re-opened u/s 147/143(3). AO noted in the re-assessment order that the assessee has received an amount of Rs.16.19 crores from M/s. Sony Mony Developers Pvt. Ltd. in which the assessee is director and 50% shareholder of the said company. According to the AO, the loan taken by the assessee from M/s. Sony Mony Devel...