“Section 2(22)(e)(i)”

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

npurchases or sales as trade advances and the remaining amount\nof advance has been treated as loans or advances within the\nmeaning of section 2(22)(e) of the Act. The learned CIT(A) without\nconsidering the relevant facts simply held that, payments in\nexcess of 200% of sales should ... computed by the AO and the balance\nexcess amount has been treated as “advance or loan” constituting\ndeemed dividend.\n17. The provisions of section 2(22)e) of the Income Tax Act, 1961\ndeals with ‘Deemed Dividend'. As per the provisions of section\n2(22)(e) of the Act, deemed

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

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

Sciences Pvt. Ltd., in excess of 150% of sales amounting to Rs.121,11,83,360/- as loans and advances for the purpose of section 2(22)(e) of the Act. Similarly, the Assessing Officer has considered excess payment by M/s. Mythri Labs Pvt. Ltd., to M/s. MSN Life Sciences ... purchases or sales as trade advances and the remaining amount of advance has been treated as loans or advances within the meaning of section 2(22)(e) of the Act. The learned CIT(A) without considering the relevant facts simply held that, payments in excess of 200% of sales should

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

appreciating the fact that the outstanding\ndebit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\n\n3. The brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability of\naccumulated profits

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

fact that the outstanding\nde'bit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\"\n\n3.\nThe brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability of\naccumulated profits

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

In the result, the appeal of assessee in ITA No

fact that the outstanding\nde debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\"\n3. The brief facts of the case are that the appellant company is\nengaged in the business of manufacturing of bulk ... after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability of\naccumulated profits

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

In the result, the appeal of assessee in ITA No

appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.\n3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing ... after examination of the ledger accounts of the recipient company, observed that the basic ingredients of ‘deemed dividend' as defined under section 2(22)(e) of the Act, such as common substantial shareholding of Shri MSN Reddy in the Appellant Company, two recipient companies and the availability of accumulated profits

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

In the result, the appeal of assessee in ITA No

appreciating the fact that the outstanding\ndebit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\"\n3. The brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability of\naccumulated profits

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

appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.\"\n3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing ... after examination of the ledger accounts of the recipient company, observed that the basic ingredients of ‘deemed dividend' as defined under section 2(22)(e) of the Act, such as common substantial shareholding of Shri MSN Reddy in the Appellant Company, two recipient companies and the availability of accumulated profits

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

In the result, the appeal of assessee in ITA No

appreciating the fact that the outstanding\ndebit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\"\n3. The brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability of\naccumulated profits

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

appreciating the fact that the outstanding\ndebit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of section 2(22)(e) of the\nAct.\"\n3.\nThe brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... nThe AO, after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability

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

Appeal are dismissed

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

appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing ... after examination of the ledger accounts of the recipient company, observed that the basic ingredients of ‘deemed dividend’ as defined under section 2(22)(e) of the Act, such as common substantial shareholding of Shri MSN Reddy in the Appellant Company, two recipient companies and the availability of accumulated profits

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

appreciating the fact that the outstanding\ndebit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact\nloan/advance which attracts the provisions of Section 2(22)(e) of the\nAct.\"\n3. The brief facts of the case are that the appellant company is\nengaged in the business of manufacturing ... nThe AO, after examination of the ledger accounts of the\nrecipient company, observed that the basic ingredients of ‘deemed\ndividend' as defined under section 2(22)(e) of the Act, such as\ncommon substantial shareholding of Shri MSN Reddy in the\nAppellant Company, two recipient companies and the availability

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

Appeal are dismissed

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

appreciating the fact that the outstanding debit balance of M/s. MSN Laboratories Pvt. Ltd. is in fact loan/advance which attracts the provisions of section 2(22)(e) of the Act.” 3. The brief facts of the case are that the appellant company is engaged in the business of manufacturing ... after examination of the ledger accounts of the recipient company, observed that the basic ingredients of ‘deemed dividend’ as defined under section 2(22)(e) of the Act, such as common substantial shareholding of Shri MSN Reddy in the Appellant Company, two recipient companies and the availability of accumulated profits

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

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

appellant company cannot be construed as excess payments which fall under the scope of "advances or loans" within the meaning of section 2(22)(e) of the Act. 3.2. In the facts and circumstances of the case, the Ld.CIT(A) ought to have appreciated that the transactions between the appellant ... funds on a need basis and such transactions do not fall under the ambit of "advances or loans" within the meaning of section 2(22)(e) of the Act.” 3.3. In the facts and circumstances of the case, the Ld.CIT(A) ought to have appreciated that deemed dividend

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

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

appellant company cannot be construed as excess payments which fall under the scope of "advances or loans" within the meaning of section 2(22)(e) of the Act. 3.2. In the facts and circumstances of the case, the Ld.CIT(A) ought to have appreciated that the transactions between the appellant ... funds on a need basis and such transactions do not fall under the ambit of "advances or loans" within the meaning of section 2(22)(e) of the Act.” 3.3. In the facts and circumstances of the case, the Ld.CIT(A) ought to have appreciated that deemed dividend