Sec. 2(22)(e) not applicable to inter banking transactions between group concerns

Neha Home Builders (P.) Ltd. Vs DCIT (ITAT Mumbai)

Conclusion: Since the transaction between assessee-company and other group concern were in the nature of current account and inter banking account containing both types of entries i.e., receipts and payments and assessee was neither the beneficial nor the registered shareholder of the company, therefore, the amount received from other group concern could not be brought in the purview of loans and advances so as to attract Section 2(22)(e).

Held: Assessee was a company engaged in the business of real estate construction – B

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