401 orders · Page 9 of 9
The High Court held that the Revenue failed to substantiate the existence of any substantial questions of law. Regarding Section 80Q, the Court found no basis for the Revenue's challenge, implying the assessee's method of profit calculation and deduction was acceptable. Concerning Section 2(22)(e), the Court ruled that the amounts received by the assessee from its subsidiary were part of regular business transactions, properly accounted for, and facilitated by advance deposits. Applying judicial precedents, these amounts could not be treated as 'loan' or 'advance' to be considered 'deemed dividend'. The Court affirmed the ITAT's decision to dismiss the Revenue's appeal on this issue. For the Section 80-IA issue in ITA.1686 of 2009, the Court noted that the matter was remanded by the CIT(A) and upheld by the Tribunal, and found no tenable grounds to interfere with this decision. Therefore, all appeals were dismissed.
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