AO cannot set-off of brought forward loss before allowing remuneration to partner

Rajmal Lakhichand Vs JCIT (ITAT Pune) Deemed dividend under section 2(22)(e) attracted even in case of ‘beneficial shareholder’ and not only in case of registered shareholder Provisions of section 2(22)(e) get attracted not only in the case of registered share holder but also in the case of concern in which such shareholder is a member or partner having substantial interest. In the present case as pointed earlier the assessee firm is holding share in group companies through Shri Ishwarlal S. Lalwani, who is having 40% share in the assessee firm. Hence, Shri Ishwarlal S. Lalwani has subst...