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SECTION 2(22) OF THE INCOME-TAX ACT, 1961 – DEEMED DIVIDEND

Loans and advances to shareholders : Where Assessing Officer had made an addition treating loan advanced by assessee’s group company (IG3) to assessee as deemed dividend under section 2(22)(e), in view of fact that neither assessee nor its shareholders were shareholders of IG3 as on date of advancing of loans and there were no common registered and beneficial shareholders between IG3 and assessee on date of advancing of loans, Commissioner (Appeals) had rightly deleted impugned additions – Deputy Commissioner of Income-tax, Central Circle 2(2) v. Mukunda Land Developers (P.) Ltd. – [2024] 160 taxmann.com 291 (Chennai – Trib.)

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