209 CTR 97 5. Puneet Bhagat v. ITO

157 ITD 353Income Tax Appellate Tribunal#9430 most cited

What is 209 CTR 97 5. Puneet Bhagat v. ITO authority for?

Loans received by a company are treated as deemed dividends in the hands of shareholders in proportion to their shareholdings under section 2(22)(e) of the Income Tax Act.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2019.

Also referred to as

Puneet Bhagat v. ITO · 157 ITD 353 · section 2(22)(e) · deemed dividend · loans and advances to shareholders · company loans · shareholder loans · ITAT Delhi

Judgments citing 209 CTR 97 5. Puneet Bhagat v. ITO

DCIT, New Delhi vs. M/S. Saamag Developers Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 4058/DEL/2015[2011-12]Status: DisposedITAT Delhi08 Jul 2019AY 2011-12

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

…) where Hon’ble Madras High Court held that Amount of impugned excess withdrawals, even though adjusted against credit balance before close of year, was assessable as deemed dividend in assessee's hands in terms of section 2(22)(e) 2- Puneet Bhagat v. ITO [157 ITD 353) Where Hon’ble ITAT Delhi held that deemed dividend- Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 3. Sunil Kapoor Vs CIT T20151 63 taxmann.com 97 (Madras)/r20151 235 Taxman 279 (Madras) where Hon’ble Madras High Court held that…

DCIT, New Delhi vs. M/S. Saga Developers Pvt. Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 2603/DEL/2014[2007-08]Status: DisposedITAT Delhi08 Jul 2019AY 2007-08

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

…) where Hon’ble Madras High Court held that Amount of impugned excess withdrawals, even though adjusted against credit balance before close of year, was assessable as deemed dividend in assessee's hands in terms of section 2(22)(e) 2- Puneet Bhagat v. ITO [157 ITD 353) Where Hon’ble ITAT Delhi held that deemed dividend- Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 3. Sunil Kapoor Vs CIT T20151 63 taxmann.com 97 (Madras)/r20151 235 Taxman 279 (Madras) where Hon’ble Madras High Court held that…

DCIT, New Delhi vs. M/S. Saamag Infrastructure Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 2600/DEL/2014[2007-08]Status: DisposedITAT Delhi08 Jul 2019AY 2007-08

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

…) where Hon’ble Madras High Court held that Amount of impugned excess withdrawals, even though adjusted against credit balance before close of year, was assessable as deemed dividend in assessee's hands in terms of section 2(22)(e) 2- Puneet Bhagat v. ITO [157 ITD 353) Where Hon’ble ITAT Delhi held that deemed dividend- Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 3. Sunil Kapoor Vs CIT T20151 63 taxmann.com 97 (Madras)/r20151 235 Taxman 279 (Madras) where Hon’ble Madras High Court held that…

DCIT, New Delhi vs. M/S. Saamag Construction Ltd., New Delhi

In the result, the Revenue’s appeal stand dismissed

ITA 2599/DEL/2014[2006-07]Status: DisposedITAT Delhi08 Jul 2019AY 2006-07

Bench: Shri H.S. Sidhu & Shri B.R.R. Kumaray 2006-07

For Appellant: Sh. M.P. RASTOGI, ADVFor Respondent: Sh. S.S. RANA, CIT(DR)
Section 132Section 132(1)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 69C

…) where Hon’ble Madras High Court held that Amount of impugned excess withdrawals, even though adjusted against credit balance before close of year, was assessable as deemed dividend in assessee's hands in terms of section 2(22)(e) 2- Puneet Bhagat v. ITO [157 ITD 353) Where Hon’ble ITAT Delhi held that deemed dividend- Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 3. Sunil Kapoor Vs CIT T20151 63 taxmann.com 97 (Madras)/r20151 235 Taxman 279 (Madras) where Hon’ble Madras High Court held that…

DCIT, Central Circle- 19, New Delhi vs. Forum Sales Pvt. Ltd., New Delhi

In the result, the appeals filed by the revenue are dismissed and appeals filed by the assessee are partly allowed

ITA 3249/DEL/2018[2014-15]Status: DisposedITAT Delhi22 Oct 2018AY 2014-15

Bench: Sh. R.K. Panda & Smt. Beena Pillai

Section 132Section 142Section 153

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. R.K. PANDA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No.2471/Del/2018 to 2472/Del/2018 Assessment Year: 2013-14 and 2014-15 Forum Sales Pvt. Ltd. ACIT Vs C-134, Ground Floor, Central Circle -19 Defence Colony, New Delhi New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) ITA No.3248/Del/2014 to 3249/Del/2018 Assessment Year: 2013-14 and 2014-15 DCIT Forum Sales Pvt. Ltd. Vs Central Circle-19 C-134, Ground Floor, New Delhi Defence Colony, New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) Assessee by…

DCIT, Central Circle- 19, New Delhi vs. Forum Sales Pvt. Ltd., New Delhi

In the result, the appeals filed by the revenue are dismissed and appeals filed by the assessee are partly allowed

ITA 3248/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Oct 2018AY 2013-14

Bench: Sh. R.K. Panda & Smt. Beena Pillai

Section 132Section 142Section 153

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. R.K. PANDA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No.2471/Del/2018 to 2472/Del/2018 Assessment Year: 2013-14 and 2014-15 Forum Sales Pvt. Ltd. ACIT Vs C-134, Ground Floor, Central Circle -19 Defence Colony, New Delhi New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) ITA No.3248/Del/2014 to 3249/Del/2018 Assessment Year: 2013-14 and 2014-15 DCIT Forum Sales Pvt. Ltd. Vs Central Circle-19 C-134, Ground Floor, New Delhi Defence Colony, New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) Assessee by…

Forum Sales Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 19, New Delhi

In the result, the appeals filed by the revenue are dismissed and appeals filed by the assessee are partly allowed

ITA 2472/DEL/2018[2014-15]Status: DisposedITAT Delhi22 Oct 2018AY 2014-15

Bench: Sh. R.K. Panda & Smt. Beena Pillai

Section 132Section 142Section 153

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. R.K. PANDA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No.2471/Del/2018 to 2472/Del/2018 Assessment Year: 2013-14 and 2014-15 Forum Sales Pvt. Ltd. ACIT Vs C-134, Ground Floor, Central Circle -19 Defence Colony, New Delhi New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) ITA No.3248/Del/2014 to 3249/Del/2018 Assessment Year: 2013-14 and 2014-15 DCIT Forum Sales Pvt. Ltd. Vs Central Circle-19 C-134, Ground Floor, New Delhi Defence Colony, New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) Assessee by…

Forum Sales Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 19, New Delhi

In the result, the appeals filed by the revenue are dismissed and appeals filed by the assessee are partly allowed

ITA 2471/DEL/2018[2013-14]Status: DisposedITAT Delhi22 Oct 2018AY 2013-14

Bench: Sh. R.K. Panda & Smt. Beena Pillai

Section 132Section 142Section 153

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. R.K. PANDA, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER ITA No.2471/Del/2018 to 2472/Del/2018 Assessment Year: 2013-14 and 2014-15 Forum Sales Pvt. Ltd. ACIT Vs C-134, Ground Floor, Central Circle -19 Defence Colony, New Delhi New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) ITA No.3248/Del/2014 to 3249/Del/2018 Assessment Year: 2013-14 and 2014-15 DCIT Forum Sales Pvt. Ltd. Vs Central Circle-19 C-134, Ground Floor, New Delhi Defence Colony, New Delhi -110024 PAN AAACF0285H (APPELLANT) (RESPONDENT) Assessee by…

ACIT, New Delhi vs. Mrs. Seema Devi Bansal, New Delhi

In the result, the Revenue’s appeal stands dismissed

ITA 6462/DEL/2014[2010-11]Status: DisposedITAT Delhi18 Jul 2018AY 2010-11

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. K. Tewari, Sr. DR
Section 142(1)Section 143(1)Section 143(3)Section 148Section 2Section 2(22)(e)

…sed as conduits by assessee; that ‘A’ had made payments to ‘B’ and ‘C’ for benefit of assessee, which enabled him to buy nine per cent RBI Relief Bonds and upheld finding of Assessing Officer. Upheld addition u/s 2(22(e) of I.T. Act. 4. Puneet Bhaqat v. ITO (157 ITD 353) Where Hon’ble ITAT Delhi held that deemed dividend-Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 5. Addl CIT Vs Shri Chandrakant V Gosalia [2015]-TIQL- 1187-lTAT-MUM where Hon’ble ITAT Delhi held that mere repayment of money borr…

ACIT, New Delhi vs. Sh. Sanjay Passi, New Delhi

In the result, the Revenue’s appeal as well as Assessee’s Cross

ITA 1450/DEL/2015[2012-13]Status: DisposedITAT Delhi11 Jul 2018AY 2012-13

Bench: Shri H.S. Sidhu & Shri Prashant Maharishi

For Appellant: Sh. V.K. Agarwal, A.RFor Respondent: Sh. S.S. Rana, CIT(DR)
Section 127Section 132Section 142(1)Section 143(1)Section 143(2)Section 153ASection 2(22)(e)

…as conduits by assessee; that 'A' had made payments to 'B' and 'C' for benefit of' assessee, which enabled him to buy nine per cent RBI Relief Bonds and upheld finding of Assessing Officer. Upheld addition u/s 2(22(e) of I.T. Act 4. Puneet Bhagat v. ITO (157 ITD 353) Where Hon'ble IT AT Delhi held that deemed dividend-Loans and advances to share holders- Loans received by the company would be treated as deemed dividend in hands of P and S in proportion to their shareholdings. 5. Sunil Kapoor Vs CIT [2015] 63 taxmann.com 97 (Madras)/[2015] 235 Taxman 279 (Madras) where Hon'ble Madras High Court held tha…

Mr. Jitendra Kumar Gupta, Meerut vs. ACIT, Meerut

In the result, the Appeal of the is allowed

ITA 274/DEL/2016[2012-13]Status: DisposedITAT Delhi29 Nov 2017AY 2012-13

Bench: Shri H.S. Sidhu & Shri L.P. Sahu

For Appellant: Sh. Sumit Goyal, CAFor Respondent: Sh. Kaushlendra Tiwari, Sr. DR
Section 14(3)Section 142(1)Section 143(2)Section 2(22)Section 2(22)(e)Section 234B

…sed as conduits by assessee; that 'A' had made payments to 'B' and 'C' for benefit of assessee, which enabled him to buy nine per cent RBI Relief Bonds and upheld finding of Assessing Officer. Upheld addition u/s 2(22(e) of I.T. Act. 4. Puneet Bhagat v. ITO (157 ITD 353) Where Hon'ble ITAT Delhi held that deemed dividend- Loans and advances to share holders-Loans received ,by the company would be treated as deemed dividend in hands of P and S in proportion to theirshareholdings. 5. Addl CIT Vs Shri Chandrakant V Gosalia [2015- TIOL-1187-ITAT-MUM] where Hon'ble ITAT Delhi held that mere repayment of money borr…

209 CTR 97 5. Puneet Bhagat v. ITO (157 ITD 353) — Cited in 11 Judgments | BharatTax