Deemed dividend provisions u/s 2(22)(e) doesn’t apply to advance for business transaction

Vishnu Aggarwal Vs ITO (ITAT Delhi)

ITAT Delhi held that the amounts advanced for business transaction between the parties would not fall within the definition of deemed dividend under section 2(22)(e) of the Act.

Facts- AO found from the audit report of the proprietary concern of the assessee that he had availed of loan or deposit of Rs. 1,60,25,000/- from M/s. Singhal Metalloys Pvt. Ltd. in which company the assessee is also a Director having substantial shareholding. The same liability of Rs. 1,60,

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