Issues in Corporate Taxation. - jb nagar cpe study circle of wirc of icai

CIT (Appeal)’s observations and decision
• The sum received as loan/advance during the relevant assessment year
could only be treated as income by way of “deemed dividend”
• The carried forward balance could not be treated as deemed dividend.
Tribunal’s observations
• The Tribunal deleted the addition on the ground that the granting of
loans was a substantial part of the business of AMPL and so the loan
could not be treated as ”deemed income” in the hands of the assessee.
August, 2011
CA Sanjeev Lalan, Singrodia Goyal &
Co. Presentation at JB Nagar CPE Study
Circle
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