Expense incurred by holding company on behalf of subsidiary company cannot be treated as deemed dividend

DCIT Vs Uniparts India Ltd (ITAT Delhi) ITAT Delhi held that expense incurred by holding company on behalf of subsidiary company which is not in the nature of loan cannot be treated as deemed dividend u/s. 2(22)(e) of the Income Tax Act. Facts- During assessment proceedings, Assessing Officer observed that assessee has received a loan of Rs.6,43,40,824/- from Gripwel Fasteners Pvt. Ltd. (GFPL) during the year. As per the balance sheet of the assessee under Note 12 Non-current Investment, GFPL is mentioned as a wholly owned subsidiary of the assessee. AO observed that a substantial shareholding...