Deemed Dividend not applicable to Current Account Transactions

M/s Sree Krishna Gyanodya Flour Mills Pvt. Ltd. Vs. Pr. CIT (ITAT Kolkata)

The purpose of Section 2(22)(e) of the Act is to tax the benefit extended by private limited company to its shareholders holding shares not less than 10% as beneficial owner of shares (not being shares entitled to a fixed rate of dividend income). There is no dispute with regard to shareholding of the assessee. Now coming to the amount of advance taken by assessee, we note that assessee has not only taken loan / advance from SVPL, but also it has sometime given advance to SVPL. Thus, there wa

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