Income Tax : Gain insights on Deemed Dividends under the Income Tax Act: Understand taxability, TDS applicability, and key exemptions for optim...
CA, CS, CMA : Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover i...
Income Tax : The dividend income received by non-resident individuals, including Foreign Portfolio Investors (FPIs) and Non-Resident Indian cit...
Income Tax : Understand the tax implications of bonus shares in deemed dividends. Explore the case of PCIT vs. Dr. Ranjan Pai and its impact on...
Income Tax : The meaning of the expression ‘substantial part of business’ for the purpose of Section 2(22)(e) Introduction Section ...
Income Tax : ITAT Ahmedabad held that passing of revisionary order by PCIT u/s. 263 of the Income Tax Act without giving proper and adequate op...
Income Tax : ITAT Bangalore rules that deemed dividend u/s 2(22)(e) can't be assessed by double deeming unless the assessee receives a direct b...
Income Tax : The department issued notice u/s. 148A(b) of the Income Tax Act, 1961, alleging that the petitioner had received loan from its 100...
Income Tax : Read about the ITAT Chennai case between DCIT and Gemini Traze RFID Pvt. Ltd. regarding deemed dividend status under Section 2(22)...
Income Tax : In DCIT Vs Eko Diagnostic Pvt. Ltd., ITAT Kolkata rules that Section 2(22) of Income Tax Act doesn't apply to non-beneficiary shar...
Income Tax : Section 2(22) clause (e) of the Income Tax Act, 1961 (the Act) provides that dividend includes any payment by a company, not being...
DCIT Vs J. P. Iscon Ltd. (ITAT Ahmedabad) The brief facts leading to the case is this that the assessee had given inter-corporate deposit to six subsidiaries companies namely Dhanlaxmi Infrastructure Pvt. Ltd., Amit Intertrade Pvt. Ltd., Dhwani Infrastructure Pvt. Ltd., Rich Infrastructure Pvt. Ltd., Gujarat Mall Management Co. Pvt. Ltd. & Palitana Sugars Mills […]
ITO Vs GRA Enterprises (ITAT Delhi) Assessing Officer while framing the assessment notice observed that the assessee had received total unsecured laon expenditure of Rs. 22,21,29,723/-, during the year out of which an amount of Rs. 950,000,00/- was received from M/s Telecare Network India (P), a closely held company having its office at Zen House, […]
We hold that there is no question of treating the amount withdrawn by the assessee as partner from the partnership firm namely M/s SKA Enterprises in the nature of loan and advance and treat it as deemed dividend under section 2(22)(e) of the Income Tax Act. None of the ingredients of section 2(22)(e) stand satisfied in the instant case.
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 […]
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.
TCI Exim Pvt. Ltd. Vs ACIT (ITAT Delhi) The Delhi bench of the Income Tax Appellate Tribunal (ITAT), Delhi bench has held that loan on interest received from the sister concern to fulfill the enhanced requirement of working capital for export orders does not attract the provisions of deemed dividend under section 2(22)(e) of the […]
Issue: Whether gift or amount paid by a closely held company to relative of shareholder will be treated as deemed dividend? In this article we are going to analyse a situation in which a company has gifted Rs. 50,000/- to one of shareholders’s son and AO has consider the gift as deemed dividend. PROBLEM: Mr. […]
Practical application of Section 185 and Section 186 of Companies Act,2013 read with Section 2(22)(e) of Income Tax Act, 1961 and consequences on non- compliance’s of these sections. Let’s summarise these sections and understand the provision of relevant acts. Section 186 of Companies Act,2013 – Whether Loan, advance or guarantee is allowed to Directors or […]
INCOME TAX QUESTIONS & ANSWERS SERIES PART -V Today we are going to consider problem based on provisions of Sections 2(22)( e) of the Income Tax Act, 1961. PROBLEM :– Mr. X holds 25% voting power in ABC (P)Ltd., he permits his own land to be mortgaged to a bank for enabling the company to […]
ITAT Delhi upholds addition of Rs. 18.75 crore as deemed dividend in Anil Nanda’s case, citing substantial shareholding and indirect benefits. Appeal dismissed.
