#Section 2(22)(e)
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201 articlesIncome Tax

Income Tax
Accumulated Profits for deemed dividend is to be arrived after allowing Depreciation as per Income Tax Act
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Current profit not to be included in accumulated profit to determine deemed dividend
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Loan or advances to shareholder which further benefits company not covered within ambit of deemed dividend
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Deemed Dividend Taxable in the hands of Individual shareholder not an entity which does not hold shares
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Deemed Dividend – ITAT allows appellant to submit additional evidences before AO
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‘Security Premium Reserve’ not part of accumulated profits u/s 2(22)(e)
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Provisions of Deemed Dividend provisions not applicable to Advancement of Loan in Ordinary Course of Business
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Sections 2(22)(e) not applies to loans from sister concern on commercial basis
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Section 2(22)(e) addition not justified for business expenses of company
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Deemed dividend provision not invocable on recipient of loan not being shareholder in payer company
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No Addition for ‘Deemed Dividend’ if payment to person holding substantial interest not established
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Advance for Business Transactions Cannot be Treated as Deemed Dividend
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Loan to assessee cannot be treated as deemed dividend when Assessee given personal Security as collateral for loan of Company
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