← All Phrases

“Section 2(22)(e)(ii)”

Section References (mined)Section 2Section 2(22)(e)(ii)22 judgments

UNIVERSAL AUTO GEARS LLP,KOLAR vs. ACIT, CIRCLE-4(2)(1), BANGALORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1370/BANG/2025[2016-17]Status: DisposedITAT Bangalore12 Nov 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 2(22)(e)

substantial stake in the assessee, in order to protect the assessee’s interest, the said loan was offered. The AO relied on section 2(22)(e)(ii) of the Act and concluded that the loan amount of Rs. 3,73,28,315/- was liable to be taxed u/s. 2(22

DCIT, NEW DELHI vs. M/S GEN X COMMODITIES (P) LTD.,, NEW DELHI

In the result, the appeal of the Revenue is dismissed

ITA 3560/DEL/2016[2010-11]Status: DisposedITAT Delhi25 Jul 2025AY 2010-11

Bench: Shri Mahavir Singh & Shri Amitabh Shukla[Assessment Year : 2010-11] Dcit Vs M/S. Gen X Commodities (P) Ltd., Central Circle-29 Fa-45, Shivaji Enclave New Delhi New Delhi-110027 Pan-Aaaca2303H Appellant Respondent Shri Jitender Singh, Cit Dr Revenue By Assessee By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Date Of Hearing 26.06.2025 Date Of Pronouncement 25.07.2025

Section 14ASection 2(22)(e)Section 250(6)

ordinary course of its business where the lending of money is a substantial part of the business of the company [section 2(22)(e)(ii)] Le., there is no deemed dividend only if the lending of moneys is by a company which is engaged in the business of money lending ... into the business of lending of money, the payments made by it to the assessee-company would therefore be covered by section 2(22)(e)(ii) and consequently payments even for business transactions would be a deemed dividend. We do not agree. The Tribunal has dealt with this aspect

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. SATYANARAYANA REDDY MANNE, HYDREABAD

In the result, appeal filed by the Assessee is allowed and\nappeal filed by the Revenue is dismissed

ITA 472/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18
For Appellant: CA M.V. Prasad andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 153ASection 251(1)(a)

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\nA\" BENCH: HYDERABAD\nBEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT\nAND\nSHRI

SATYANARAYANA REDDY MANNE,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeal filed by the Assessee is allowed and appeal filed by the Revenue is dismissed

ITA 382/HYD/2025[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA M.V. Prasad and Shri K.S. Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 153ASection 251(1)(a)

business of lending money, the payments made by it to the assessee-company would be covered by section 2(22)(e)(ii) and, consequently, payment even for business transactions would be a deemed dividend. There was no merit in the contentions of the revenue. The provision of section 2(22 ... transactions do not fall within section 2(22)(e), there is no need to go further to 48 ITA.Nos.382 & 472/Hyd./2025 section 2(22)(e)(ii). The provision of section 2(22)(e)(i) gives an example only of one of the situations where the loan/advance will

M/S THANJAVUR COMMERECE PVT; LTD.,,NAGPUR vs. A,C.I.T CENT CIR. 1(2), NAGPUR

In the result, appeal by the assessee is allowed

ITA 182/NAG/2016[2011-12]Status: DisposedITAT Nagpur15 May 2025AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 132Section 139(1)Section 143(2)Section 144Section 154Section 2(22)(e)

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR BENCH, NAGPUR BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER AND SHRI K.M. ROY

ACIT., CENTRAL CIRCLE-2(4), , HYDERABAD vs. M/S. MAITHRI LABORATORIES PRIVATE LIMITED, HYDERABAD

In the result, both the appeals of assessee and the Revenue\nare partly allowed

ITA 1124/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 143(3)Section 153ASection 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\n\nThe provision ... held that the business\ntransactions do not fall within section 2(22)(e), there is\nno need to go further to section 2(22)(e)(ii). The provision\nof section 2(22)(e)(i) gives an example only of one of the\nsituations where the loan/advance will not be treated

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. M/S. MSN LIFE SCIENCES PVT. LTD., HYDERABAD

ITA 1123/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\nThe provision ... held that the business\ntransactions do not fall within section 2(22)(e), there is\nno need to go further to section 2(22)(e)(ii). The provision\nof section 2(22)(e)(i) gives an example only of one of the\nsituations where the loan/advance will not be treated

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. MSN PHARMACHEM PVT. LTD., HYDERABAD

In the result, the appeal of assessee in ITA No

ITA 1122/HYD/2024[2019-20]Status: DisposedITAT Hyderabad04 Feb 2025AY 2019-20
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\nThe provision ... held that the business\ntransactions do not fall within section 2(22)(e), there is\nno need to go further to section 2(22)(e)(ii). The provision\nof section 2(22)(e)(i) gives an example only of one of the\nsituations where the loan/advance will not be treated

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeal of assessee in ITA No

ITA 1072/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

business of lending money, the payments made by it to the assessee-company would be covered by section 2(22)(e)(ii) and, consequently, payment even for business transactions would be a deemed dividend. There was no merit in the contentions of the revenue. The provision of section 2(22 ... held that the business transactions do not fall within section 2(22)(e), there is no need to go further to section 2(22)(e)(ii). The provision of section 2(22)(e)(i) gives an example only of one of the situations where the loan/advance will not be treated

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeal of assessee in ITA No

ITA 1071/HYD/2024[2019-20]Status: DisposedITAT Hyderabad04 Feb 2025AY 2019-20
Section 132Section 143(2)Section 153ASection 153A(1)Section 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\nThe provision ... held that the business\ntransactions do not fall within section 2(22)(e), there is\nno need to go further to section 2(22)(e)(ii). The provision\nof section 2(22)(e)(i) gives an example only of one of the\nsituations where the loan/advance will not be treated

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1068/HYD/2024[2014-15]Status: DisposedITAT Hyderabad04 Feb 2025AY 2014-15
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

business of lending money, the payments made by it to the assessee-company would be covered by section 2(22)(e)(ii) and, consequently, payment even for business transactions would be a deemed dividend. There was no merit in the contentions of the revenue. The provision of section 2(22 ... held that the business transactions do not fall within section 2(22)(e), there is no need to go further to section 2(22)(e)(ii). The provision of section 2(22)(e)(i) gives an example only of one of the situations where the loan/advance will not be treated

MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeal of assessee in ITA No

ITA 1067/HYD/2024[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\nThe provision ... held that the business\ntransactions do not fall within section 2(22)(e), there is\nno need to go further to section 2(22)(e)(ii). The provision\nof section 2(22)(e)(i) gives an example only of one of the\nsituations where the loan/advance will not be treated

MAITHRI LABORATORIES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1059/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 143(3)Section 153ASection 2(22)(e)

nnot in the business of lending money, the payments\nmade by it to the assessee-company would be covered\nby section 2(22)(e)(ii) and, consequently, payment even\nfor business transactions would be a deemed dividend.\nThere was no merit in the contentions of the revenue.\n[Para

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1053/HYD/2024[2014-15]Status: DisposedITAT Hyderabad04 Feb 2025AY 2014-15
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 153ASection 153A(1)Section 2(22)(e)

{ "clean_text": "आयकर अपीलीय अधिकरण, हैदराबाद पीठ में\nIN THE INCOME TAX APPELLATE TRIBUNAL\nHYDERABAD BENCHES “A”, HYDERABAD\nBEFORE\nSHRI

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

ITA 1052/HYD/2024[2013-14]Status: DisposedITAT Hyderabad04 Feb 2025AY 2013-14

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M.V. Prasad, C.A. and Shri K.S. Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A” , HYDERABAD BEFORE SHRI LALIET KUMAR

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1051/HYD/2024[2012-13]Status: DisposedITAT Hyderabad04 Feb 2025AY 2012-13
For Appellant: Shri M.V. Prasad, C.A. andFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 153ASection 153A(1)Section 2(22)(e)

{ "clean_text": "आयकर अपीलीय अधिकरण, हैदराबाद पीठ में\nIN THE INCOME TAX APPELLATE TRIBUNAL\nHYDERABAD BENCHES “A”, HYDERABAD\nBEFORE\nSHRI

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

Appeal are dismissed

ITA 1050/HYD/2024[2011-12]Status: DisposedITAT Hyderabad04 Feb 2025AY 2011-12

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M.V. Prasad, C.A. and Shri K.S. Rajendra KumarFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 153ASection 153A(1)Section 2(22)(e)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “A” , HYDERABAD BEFORE SHRI LALIET KUMAR

AKHIL TANEJA,NEW DELHI vs. ITO WARD 1(1), GURGAON

In the result, the appeal of the Revenue is dismissed

ITA 3560/DEL/2023[A.Y. 2013-14]Status: DisposedITAT Delhi07 Jan 2025

Bench: Shri Mahavir Singh & Shri Amitabh Shukla[Assessment Year : 2010-11] Dcit Vs M/S. Gen X Commodities (P) Ltd., Central Circle-29 Fa-45, Shivaji Enclave New Delhi New Delhi-110027 Pan-Aaaca2303H Appellant Respondent Shri Jitender Singh, Cit Dr Revenue By Assessee By Shri Ved Jain, Adv. & Shri Ayush Garg, Ca Date Of Hearing 26.06.2025 Date Of Pronouncement 25.07.2025

Section 14ASection 2(22)(e)Section 250(6)

ordinary course of its business where the lending of money is a substantial part of the business of the company [section 2(22)(e)(ii)] Le., there is no deemed dividend only if the lending of moneys is by a company which is engaged in the business of money lending ... into the business of lending of money, the payments made by it to the assessee-company would therefore be covered by section 2(22)(e)(ii) and consequently payments even for business transactions would be a deemed dividend. We do not agree. The Tribunal has dealt with this aspect

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

ITA 885/HYD/2024[2020-21]Status: DisposedITAT Hyderabad08 Nov 2024AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 2(22)(e)

business of lending money, the payments made by it to the assessee- company would be covered by section 2(22)(e)(ii) and, consequently, payment even for business transactions would be a deemed dividend. There was no merit in the contentions of the revenue. The provision of section 2(22 ... held that the business transactions do not fall within section 2(22)(e), there is no need to go further to section 2(22)(e)(ii). The provision of section 2(22)(e)(i) gives an example only of one of the situations where the loan/advance will not be treated

MSN PHARMACHEM PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee for assessment years 2019-20 and 2020-21 are partly allowed

ITA 884/HYD/2024[2019-20]Status: DisposedITAT Hyderabad08 Nov 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Ble

For Appellant: Shri M.V. Prasad, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 132Section 139(1)Section 143(3)Section 153ASection 2(22)(e)

business of lending money, the payments made by it to the assessee- company would be covered by section 2(22)(e)(ii) and, consequently, payment even for business transactions would be a deemed dividend. There was no merit in the contentions of the revenue. The provision of section 2(22 ... held that the business transactions do not fall within section 2(22)(e), there is no need to go further to section 2(22)(e)(ii). The provision of section 2(22)(e)(i) gives an example only of one of the situations where the loan/advance will not be treated

Showing 1–20 of 22 · Page 1 of 2