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Deemed Dividend U/s 2(22)(e) Largely Deleted & Sec.54 Deduction Allowed
Case Law Details
- Case Name
- Atul Bansal Vs ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2013-14
- Courts
- All ITAT, ITAT Delhi
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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. Ltd., Par Excellence Leasing & Financial Services Ltd.). CIT(A) deleted most additions after verifying shareholding & nature of rese...
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