Deemed Dividend Addition Remanded Due to Year-of-Receipt Mismatch

Afsana Begum Vs ACIT (ITAT Kolkata) Deemed dividend year mismatch unsettled: ITAT Guwahati remands 2(22)(e) issue for fresh examination Guwahati Tribunal set aside order of CIT(A)/NFAC confirming addition of ₹2.25 crore u/s 2(22)(e) & restored matter for de-novo adjudication. Tribunal noted that Assessee contended no loan or advance was received during AY 2020-21 & that the impugned amount pertained to an earlier year, whereas AO had treated outstanding balance as deemed dividend merely because Assessee was a director with substantial shareholding & company had sufficient accumul...