Deemed dividend not attracted on Loan Taken on interest

DCIT Vs Heilgers Development & Construction Company Pvt. Ltd (ITAT Kolkata) The loan amounts in question treated as deemed dividend u/s 2(22)(e) by the AO were taken by the assessee-company from the three concerns on interest and since the said lending companies were compensated by interest paid by the assessee-company on the loans, the assessee-company in real sense did not derive any benefit from the said loans so as to attract the provisions of section 2(22)(e). It is noted that this contention raised on behalf of the assessee-company is duly supported by the decision of Hon’ble Calcu...