Deemed Dividend U/s 2(22)(e) Largely Deleted & Sec.54 Deduction Allowed

Atul Bansal Vs ACIT (ITAT Delhi)

This case involved cross-appeals against CIT(A) order where the AO treated huge advances of ₹71.08 Cr as deemed dividend u/s 2(22)(e) and disallowed deduction u/s 54. The Tribunal examined shareholding thresholds, accumulated profits, NBFC exception & factual matrix in detail.

Issue 1 — Deemed Dividend u/s 2(22)(e):

The AO made addition alleging loans from group companies (ABW Infrastructure Ltd., VPS Realtors Pvt. L

Please become a Premium member. If you are already a Premium member, login here to access the full content.