Section 2(22)(e)

Deemed Dividend Taxation in India

Income Tax - Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover insights into Section 194 and 2(22) of Income Tax Act....

Taxability of Deemed Dividend under Section 2(22)(e) of Income Tax Act

Income Tax - The dividend income received by non-resident individuals, including Foreign Portfolio Investors (FPIs) and Non-Resident Indian citizens (NRIs), is taxable at a rate of 20% without any deductions under the Income-tax Act....

Some Significant Cases Related To Deemed Dividends

Income Tax - 1. PCIT Vs. Dr. Ranjan Pai(2021)431 ITR 250(Krnataka) QUESTTION: Can Bonus Shares received by shareholders be taxable under head “ Income from other sources” as per provisions of Section 56(2)(x) , as they are received without consideration? ANSWER: The issue of Bonus Shares by capitalization of reserves is merely a reallocation of th...

Meaning of expression ‘substantial part of business’ for Section 2(22)(e)

Income Tax - The meaning of the expression ‘substantial part of business’ for the purpose of Section 2(22)(e) Introduction Section 2(22)(e) of the Income Tax Act, 1961 will not be attracted if the company making the payment by way of loans or advances, have made such payment in the ordinary course of its business and lending of money [&hel...

Inter-Corporate Deposit cannot be treated as loan for Section 2(22)(e)

Income Tax - The Inter-Corporate Deposit does not fall within the ambit of the expression 'loan' specified in Section 2(22)(e) of the Income Tax Act, 1961 for the purpose of treating it as deemed dividend....

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Legal fiction for deemed dividend should not be extended to broaden concept of shareholders

Pawa International Pvt Ltd Vs ACIT (ITAT Delhi) - Legal fiction created u/s. 2 (22)(e) enlarges definition of dividend only and legal fiction is not to be extended further for broadening concept of share holders....

Delhi HC: Mutual Fund Transactions Treated as Investments, Not Business Activities

PCIT Vs Wig Investment (Delhi High Court) - A pivotal ruling affirming ITAT's stance on mutual funds transactions as investments and capital contributions not deemed as dividend under Section 2(22)(e) of the Income-tax Act for AY 2006-07....

Madras HC Grants Interim Stay in Cognizant’s Tax Case Appeal against ITAT Order

Cognizant Technology Solutions India Private Limited Vs ACIT (Madras High Court) - Madras High Court halts Rs. 9403.09 Cr Income Tax demand against Cognizant Technology Solutions India. Detailed analysis and implications of the order....

Section 2(22)(e) Deemed Dividend Addition Limited to Shareholders

DCIT Vs Solitaire Realinfra Private Limited (ITAT Delhi) - Explore ITAT Delhi's ruling limiting deemed dividend addition to shareholders. Details on assessment years 2013-14, 2014-15, and 2015-16. Full text analysis....

Addition u/s. 2(22)(e) as deemed dividend unsustainable as debit balance was only an inadvertent error

Venkatachalam Mohan Vs JCIT (ITAT Chennai) - ITAT Chennai held that addition u/s. 2(22)(e) towards amount received by shareholder company treating debit balance as deemed dividend unsustainable as debit balance was only because of an inadvertent error and the same was squared off within short period....

No deemed dividend U/s. 2(22)(e) on trade advances in the nature of commercial transactions: CBDT

Circular No. 19/2017-Income Tax - (12/06/2017) - Section 2(22) clause (e) of the Income Tax Act, 1961 (the Act) provides that dividend includes any payment by a company, not being a company in which the public are substantially interested, of any sum by way of advance or loan to a shareholder, being a person who is the beneficial owner of shares...

Recent Posts in "Section 2(22)(e)"

Legal fiction for deemed dividend should not be extended to broaden concept of shareholders

Pawa International Pvt Ltd Vs ACIT (ITAT Delhi)

Legal fiction created u/s. 2 (22)(e) enlarges definition of dividend only and legal fiction is not to be extended further for broadening concept of share holders....

Delhi HC: Mutual Fund Transactions Treated as Investments, Not Business Activities

PCIT Vs Wig Investment (Delhi High Court)

A pivotal ruling affirming ITAT's stance on mutual funds transactions as investments and capital contributions not deemed as dividend under Section 2(22)(e) of the Income-tax Act for AY 2006-07....

Deemed Dividend Taxation in India

Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover insights into Section 194 and 2(22) of Income Tax Act....

Posted Under: Income Tax |

Madras HC Grants Interim Stay in Cognizant’s Tax Case Appeal against ITAT Order

Cognizant Technology Solutions India Private Limited Vs ACIT (Madras High Court)

Madras High Court halts Rs. 9403.09 Cr Income Tax demand against Cognizant Technology Solutions India. Detailed analysis and implications of the order....

Section 2(22)(e) Deemed Dividend Addition Limited to Shareholders

DCIT Vs Solitaire Realinfra Private Limited (ITAT Delhi)

Explore ITAT Delhi's ruling limiting deemed dividend addition to shareholders. Details on assessment years 2013-14, 2014-15, and 2015-16. Full text analysis....

Addition u/s. 2(22)(e) as deemed dividend unsustainable as debit balance was only an inadvertent error

Venkatachalam Mohan Vs JCIT (ITAT Chennai)

ITAT Chennai held that addition u/s. 2(22)(e) towards amount received by shareholder company treating debit balance as deemed dividend unsustainable as debit balance was only because of an inadvertent error and the same was squared off within short period....

Taxability of Deemed Dividend (Section 2(22)(e)) Limited to Shareholder

ACIT Vs Kiran Ship Breaking Company (ITAT Ahmedabad)

ITAT Ahmedabad held that addition of amount received as advances as deemed dividend in terms of section 2(22)(e) of the Income Tax Act unsustainable as assessee firm is neither registered shareholder nor beneficial shareholder. Concluded that deemed dividend is taxable only in the hands of the shareholder....

Penalty u/s 271(1)(c) not leviable in absence of concealment of particulars of income

Manoj Mittal Vs DCIT (ITAT Delhi)

ITAT Delhi held that penalty under section 271(1)(c) of the Income Tax Act not leviable since there is no concealment of particulars of income by the assessee....

ITAT upheld addition for share premium exceeding fair market value: Section 56(2)(viib)

MobiCom Technologies Pvt. Ltd. Vs ITO (ITAT Bangalore)

ITAT Bangalore held that the share premium received by the company is in excess of fair market value of the share, the addition thus made u/s. 56(2)(viib) of the Income Tax Act is found to be just and proper....

Disallowance under rule 8D(2)(ii) unjustified as interest bearing funds not applied for making investments

Apeejay Pvt. Ltd. Vs DCIT (ITAT Kolkata)

ITAT Kolkata held that there is no finding that interest bearing funds have been applied for purpose of making investment. Further, on account of sufficient availability of interest free funds, interest disallowance under rule 8D(2)(ii) unjustified....

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