Advance receipt by Lending Company in the course of business cannot be treated as Deemed Dividend

DCIT Vs Svarna Infrastructure & Builders Pvt. Ltd. (ITAT Kolkata)

The issue under consideration is whether the receipt of advance vis-a-vis no accumulated profit in case of lending company is considered as deemed dividend u/s 2(22)(e)?

ITAT states that when dividends are declared by a company, it is solely the shareholders who benefit from the transaction. No benefits accrue to the company by way of dividend distribution. Thus, section 2(22)(e) of the Act covers only s

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