Provision of Section 2(22)(e) cannot be attracted to current account transactions

M/s Mirik Commercial 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 DVPL, but also it has sometime given advance to DVPL. Thus, there was change in the b

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