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“deemed dividend”

Special Rate ProvisionsSection 2(22)(e)Section 2(22)(e)749 judgments

The decision most relied on for deemed dividend is CIT v. Ankitech (P) Ltd. (340 ITR 14), cited in 202 judgments on BharatTax.

Leading authorities on deemed dividend

CIT v. Ankitech (P) Ltd.
340 ITR 14 · 2012 · High Court
202
citing judgments

Deemed dividend under section 2(22)(e) cannot be taxed in the hands of a non-shareholder. The Supreme Court confirmed this view, affirming the Delhi High Court's decision in Ankitech.

Pradip Kumar Malhotra v. CIT
338 ITR 538 · 2011 · High Court
152
citing judgments

Section 2(22)(e) of the Income Tax Act, which addresses deemed dividends, does not apply to loans or advances provided by a company to its shareholders if these transactions occur in the normal course of business, are driven by business expediency, or are made in consideration of a benefit conferred upon the company by the shareholder. Conversely, gratuitous loans or advances given to shareholders fall within the purview of this section.

CIT v. Creative Dyeing & Printing Pvt. Ltd.
318 ITR 476 · 2009 · High Court
119
citing judgments

Genuine trade advances or amounts advanced for bona fide business transactions, driven by commercial expediency, do not fall within the definition of deemed dividend under section 2(22)(e) of the Income-tax Act.

CIT v. Raj Kumar
318 ITR 462 · 2009 · High Court
119
citing judgments

Genuine trade advances made by a company in the ordinary course of business to a shareholder do not fall within the definition of deemed dividend under Section 2(22)(e) of the Income-tax Act.

CIT v. Universal Medicare Pvt. Ltd.
324 ITR 263 · 2010 · High Court
111
citing judgments

Deemed dividend under section 2(22)(e) is assessable only in the hands of the beneficial shareholder who receives the benefit of the loan or advance, and not in the hands of the company receiving the loan.

CIT v. Mukundray K. Shah
290 ITR 433 · 2007 · Supreme Court
99
citing judgments

For Section 2(22)(e) to apply, a payment by a company must be in the nature of a loan or advance, and the company must have accumulated profits. Such payments to a concern in which a shareholder, holding more than 10% voting power, has a substantial interest are deemed dividends if the shareholder ultimately benefits, even if routed through different modes or concerns.

Bagmane Constructions (P) Ltd. v. CIT & Anr.
318 ITR 376 · 2009 · High Court
81
citing judgments

The provisions of Section 2(22)(e) regarding deemed dividends do not apply to transactions between a shareholder and a company that create mutual benefits and obligations, such as trade advances in the nature of commercial transactions.

Miss P. Sarada v. CIT
229 ITR 444 · 1998 · Supreme Court
64
citing judgments

A loan or advance from a closely held company to a shareholder is a deemed dividend under Section 2(22)(e) upon receipt, unaffected by subsequent repayment or adjustment.

Judgments citing deemed dividend

Dr. H M Venkatappa, Bengaluru vs. DCIT, Central Circle - 1(3), Bengaluru

ITA 2176/BANG/2024[2018-19]Status: DisposedITAT Bangalore02 Jun 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2018-19

For Appellant: Shri E Balasubramanian C.AFor Respondent: Shri Sridhar E, CIT and Shri Subramanian S
Section 153CSection 2(22)(e)

treating cash belonging to the company M/s Kanva Diagnostic Services Pvt Ltd found from the assessee’s residence and office of auditor as deemed dividend u/s 2(22)(e) of the Act. Page 2 of 10 3. The facts in brief are that the assessee is an individual, majority shareholder ... total of ₹2,29,85,400/- was withdrawn by Dr. Venkatappa from KDSPL for personal use and therefore, the same should be considered as deemed dividend under section 2(22)(e) of the Act, since Dr. Venkatappa is a substantial shareholder in M/s KDSPL. Thus, the AO issued show cause

Gaurav Bajaj, New Delhi vs. ITO Ward-22(3), New Delhi

ITA 3475/DEL/2019[2012-13]Status: DisposedITAT Delhi02 Jun 2025AY 2012-13

Bench: Sh. Satbeer Singh Godaraita No. 3473/Del/2019 : Asstt. Year : 2013-14 Ita No. 3474/Del/2019 : Asstt. Year : 2011-12 Ita No. 3475/Del/2019 : Asstt. Year : 2012-13 Gaurav Bajaj, Vs Income Tax Officer, 1786, 1St Floor, Bajaj House, Ward-22(3), Bhagirath Palace, New Delhi-110002 New Delhi-110006 (Appellant) (Respondent) Pan No. Aeopb3197D Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order These Assessee’S Three Appeals Ita Nos. 3473, 3474 & 3475/Del/2019, For Assessment Years 2011-12, 2012-13 & 2013-14, Arise Against The Cit(A)-8, New Delhi’S As Many Orders Dated 05.02.2019, 06.02.2019 & 18.03.2019 In Case Nos. 10589, 10590 & 10591, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR
Section 147Section 148Section 2(22)(e)

hearing that both the lower authorities have rightly invoked section 148/147 reopening mechanism against the assessee in order to assess section 2(22)(e) deemed dividends amount of Rs.15,00,000/-, in his hands, in the course of assessment framed on 08.12.2016 and partly upheld ... have given my thoughtful consideration to the assessee’s pleadings all along and the department’s vehement contentions supporting the impugned deemed dividends addition. There could be hardly any dispute that the assessee has duly filed his evidence representing the impugned sum as in the nature of commercial sale/purchase transactions

Gaurav Bajaj, New Delhi vs. ITO Ward-22(3), New Delhi

ITA 3474/DEL/2019[2011-12]Status: DisposedITAT Delhi02 Jun 2025AY 2011-12

Bench: Sh. Satbeer Singh Godaraita No. 3473/Del/2019 : Asstt. Year : 2013-14 Ita No. 3474/Del/2019 : Asstt. Year : 2011-12 Ita No. 3475/Del/2019 : Asstt. Year : 2012-13 Gaurav Bajaj, Vs Income Tax Officer, 1786, 1St Floor, Bajaj House, Ward-22(3), Bhagirath Palace, New Delhi-110002 New Delhi-110006 (Appellant) (Respondent) Pan No. Aeopb3197D Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order These Assessee’S Three Appeals Ita Nos. 3473, 3474 & 3475/Del/2019, For Assessment Years 2011-12, 2012-13 & 2013-14, Arise Against The Cit(A)-8, New Delhi’S As Many Orders Dated 05.02.2019, 06.02.2019 & 18.03.2019 In Case Nos. 10589, 10590 & 10591, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR
Section 147Section 148Section 2(22)(e)

hearing that both the lower authorities have rightly invoked section 148/147 reopening mechanism against the assessee in order to assess section 2(22)(e) deemed dividends amount of Rs.15,00,000/-, in his hands, in the course of assessment framed on 08.12.2016 and partly upheld ... have given my thoughtful consideration to the assessee’s pleadings all along and the department’s vehement contentions supporting the impugned deemed dividends addition. There could be hardly any dispute that the assessee has duly filed his evidence representing the impugned sum as in the nature of commercial sale/purchase transactions

Gaurav Bajaj, New Delhi vs. ITO Ward-22(3), New Delhi

ITA 3473/DEL/2019[2013-14]Status: DisposedITAT Delhi02 Jun 2025AY 2013-14

Bench: Sh. Satbeer Singh Godaraita No. 3473/Del/2019 : Asstt. Year : 2013-14 Ita No. 3474/Del/2019 : Asstt. Year : 2011-12 Ita No. 3475/Del/2019 : Asstt. Year : 2012-13 Gaurav Bajaj, Vs Income Tax Officer, 1786, 1St Floor, Bajaj House, Ward-22(3), Bhagirath Palace, New Delhi-110002 New Delhi-110006 (Appellant) (Respondent) Pan No. Aeopb3197D Assessee By: None Revenue By : Sh. Akhilesh Kumar Yadav, Sr. Dr Date Of Hearing: 02.06.2025 Date Of Pronouncement: 02.06.2025 Order These Assessee’S Three Appeals Ita Nos. 3473, 3474 & 3475/Del/2019, For Assessment Years 2011-12, 2012-13 & 2013-14, Arise Against The Cit(A)-8, New Delhi’S As Many Orders Dated 05.02.2019, 06.02.2019 & 18.03.2019 In Case Nos. 10589, 10590 & 10591, In Proceedings U/S 147/143(3) Of The Income Tax Act, 1961 (In Short “The Act”), Respectively.

For Appellant: NoneFor Respondent: Sh. Akhilesh Kumar Yadav, Sr. DR
Section 147Section 148Section 2(22)(e)

hearing that both the lower authorities have rightly invoked section 148/147 reopening mechanism against the assessee in order to assess section 2(22)(e) deemed dividends amount of Rs.15,00,000/-, in his hands, in the course of assessment framed on 08.12.2016 and partly upheld ... have given my thoughtful consideration to the assessee’s pleadings all along and the department’s vehement contentions supporting the impugned deemed dividends addition. There could be hardly any dispute that the assessee has duly filed his evidence representing the impugned sum as in the nature of commercial sale/purchase transactions

Seabird Marine Services Private Limited, Jamnagar vs. ACIT, Circle - 1, Jamnagar, Jamangar

ITA 83/RJT/2025[2017-18]Status: DisposedITAT Rajkot30 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

For Appellant: Shri S. N. Soparkar, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT-DR
Section 114Section 115JSection 143(3)

different transactions i.e., the capital reduction of assessee- company and capital reduction of its investee companies. (iv). considering capital reduction of assessee- company, as deemed dividend_u/s 2(22)(d) of the Act, despite the fact that capital reduction is carried out for NIL consideration. (v). considering transaction of capital ... said section creates a fiction to make the UTI as a deemed company and distribution of income received by the unitholder as a deemed dividend, by virtue of these deemed provisions, it cannot be said that it also makes the unit of the UTI a deemed share. In our opinion

Yashvardhan Gokuldas Binani, Mumbai vs. ITO 17 (3) (5), Mumbai

ITA 4133/MUM/2024[2012-13]Status: DisposedITAT Mumbai30 May 2025AY 2012-13

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Kirit SanghviFor Respondent: Shri Bhangepatil Pushkaraj Ramesh
Section 142(1)Section 144Section 147Section 148Section 2(22)(e)Section 250

significant shareholding in both the aforesaid companies (a) 16.34% in Decon Mercantile and (b) 21.47% in Francis Klein & Co. Therefore, the provisions related to deemed dividend contained in Section 2(22)(e) of the Act were attracted. Thus, the Assessing Officer had reasons to believe that income in the nature ... deemed dividend had escaped assessment and therefore, notice under Section 148 of the Act was issued to the Assessee on 28/03/2019. The Assessee failed to respond to the said notice and as a result, a show-cause notice was issued to the Assessee. Again the Assessee failed to comply with

Involute Engineering Pvt. Ltd., New Delhi vs. DCIT, Circle- 12(2), New Delhi

The appeals is allowed

ITA 6884/DEL/2019[2013-14]Status: DisposedITAT Delhi29 May 2025AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year: 2013-14 Involute Engineering Pvt. Ltd., Vs Dcit, E-30, Anand Niketan, Circle-12(2), Basement, New Delhi. New Delhi – 110 001. Pan: Aaacs2041N (Appellant) (Respondent) Assessee By : Shri Sanjay Arora, Ca; Ms Pallavi Sharma, Ca & Shri Jeetan Nagpal, Ca Revenue By : Shri Om Prakash, Sr. Dr Date Of Hearing : 01.05.2025 Date Of Pronouncement : 29.05.2025 Order Per Anubhav Sharma, Jm: This Appeal Is Preferred By The Assessee Against The Order Dated 31.05.2019 Of The Commissioner Of Income-Tax (Appeals)-22, New Delhi (Hereinafter Referred To As The Ld. First Appellate Authority Or ‘The Ld. Faa’, For Short) In Appeal No.208/18-19/Cit(A)-22, New Delhi Arising Out Of The Appeal Before It Against The Order Dated 18.03.2016, Passed U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By The Dcit, Circle- 12(2), New Delhi (Hereinafter Referred To As The Ld. Ao).

For Appellant: Shri Sanjay Arora, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 36(1)(vii)

invoking section 2(22)(e) of the Act and treating the amounts received by the Appellant from one Sara Industrial Estate Ltd as deemed dividend. In this regard, we find that Ld. AO and ld.CIT(A) have made following observations:- “10.3 Finding of the AO: “It can be seen from ... sums refunded by SIEL to the Appellant added them up to arrive at a figure of Rs. 25 lacs and treated the same as deemed dividend by invoking provisions of section 2(22)(e) of the Act without appreciating the facts placed before him which conclusively prove that the deeming

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kishore Kumar Jain, Chennai

ITA 2849/CHNY/2024[2016-17]Status: DisposedITAT Chennai26 May 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2847, 2848 & 2849 /Chny/2024 निर्धारण वर्ष / Assessment Years: 2012-13, 2013-14 & 2016-17 Assistant Commissioner Of Income Tax, Central Circle -2 (2), Chennai. Vs. Kishore Kumar Jain, 62, Bvk Sampath Road, Vepery, Chennai - 600 007. [Pan: Aahpj-0401-H] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Mr. Shivanand K Kalakeri, Cit Mr. B.Ramakrishnan, F.C.A. : 13.03.2025 : 26.05.2025 आदेश /Order Per S. R. Raghunatha: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai, All Dated 10.09.2024 & Pertains To Assessment Years 2012-13, 2013-14 & 2016-17. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, The Appeals Filed By The Revenue Are Being Heard Together & Disposed Of, By This Consolidated Order. 2. The Revenue Has Raised The Following Common Grounds Of Appeal For All The

Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 250

order u/s.143(3) r.w.s.153A dated 29.12.2018 by making addition of Rs.8,70,67,200/-, Rs.5,97,36,000/- and Rs.23,24,36,770/- as ‘Deemed Dividend' u/s 2(22)(e) of the Act for the AYs 2012-13, 2013-14 & 2016-17 respectively in the hands of the assessee stating

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kishore Kumar Jain, Chennai

In the result the three appeals filed by the revenue are dismissed

ITA 2848/CHNY/2024[2013-14]Status: DisposedITAT Chennai26 May 2025AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2847, 2848 & 2849 /Chny/2024 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2016-17 Assistant Commissioner Of Kishore Kumar Jain, Income Tax, Vs. 62, Bvk Sampath Road, Central Circle -2 (2), Vepery, Chennai. Chennai – 600 007. [Pan: Aahpj-0401-H] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Mr. Shivanand K Kalakeri, CITFor Respondent: Mr. B.Ramakrishnan, F.C.A
Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 250

order u/s.143(3) r.w.s.153A dated 29.12.2018 by making addition of Rs.8,70,67,200/-, Rs.5,97,36,000/- and Rs.23,24,36,770/- as ‘Deemed Dividend’ u/s 2(22)(e) of the Act for the AYs 2012-13, 2013-14 & 2016-17 respectively in the hands of the assessee stating ... financials of the Company. Therefore, the AO's action of treating the on- money payments, sourced from the unaccounted income of the Company as deemed dividend under Section 2(22)(e) of the Act in the hands of the Respondent is not sustainable as the funds utilized for the purchase

Assistant Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Kishore Kumar Jain, Chennai

ITA 2847/CHNY/2024[2012-13]Status: DisposedITAT Chennai26 May 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2847, 2848 & 2849 /Chny/2024 निर्धारण वर्ष / Assessment Years: 2012-13, 2013-14 & 2016-17 Assistant Commissioner Of Income Tax, Central Circle -2 (2), Chennai. (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Kishore Kumar Jain, Vs.62, Bvk Sampath Road, Vepery, Chennai - 600 007. [Pan: Aahpj-0401-H] (प्रत्यर्थी/Respondent) Mr. Shivanand K Kalakeri, Cit Mr. B.Ramakrishnan, F.C.A. 13.03.2025 26.05.2025 आदेश /Order Per S. R. Raghunatha: These Three Appeals Filed By The Revenue Are Directed Against Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Chennai, All Dated 10.09.2024 & Pertains To Assessment Years 2012-13, 2013-14 & 2016-17. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, The Appeals Filed By The Revenue Are Being Heard Together & Disposed Of, By This Consolidated Order. 2. The Revenue Has Raised The Following Common Grounds Of Appeal For All The

Section 143(2)Section 143(3)Section 153ASection 2(22)(e)Section 250

vide order u/s.143(3) r.w.s.153A dated 29.12.2018 by making addition of Rs.8,70,67,200/-, Rs.5,97,36,000/- Rs.23,24,36,770/- as ‘Deemed Dividend' u/s 2(22)(e) of the Act for the AYs 2012-13, 2013-14 & 2016-17 respectively in the hands of the assessee stating ... financials of the Company. Therefore, the AO's action of treating the on- money payments, sourced from the unaccounted income of the Company as deemed dividend under Section 2(22)(e) of the Act in the hands of the Respondent is not sustainable as the funds utilized for the purchase

ACIT Central Circle-3, Thane vs. Arun Kumar Pillai, Bengaluru

In the result, the appeal filed by the Revenue is dismissed for statistical purpose

ITA 1942/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 May 2025AY 2017-18

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Nishchit GandhiFor Respondent: DR. K. R. Subhash (CIT DR)
Section 127Section 139(1)Section 143(2)Section 153ASection 153CSection 2(22)(e)Section 250

that the addition under section 2(22)(e) of the Income Tax Act, 1961, despite the presence of seized material substantiating the nature of deemed dividend transactions and concluding that the addition was solely based on financial statements already submitted by the assessee.” 4. Brief facts of the case

ACIT, Central Circle -3, Thane vs. Arun Kumar Pillai, Bengaluru

In the result, the appeal filed by the Revenue is dismissed for statistical purpose

ITA 1941/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 May 2025AY 2016-17

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Nishchit GandhiFor Respondent: DR. K. R. Subhash (CIT DR)
Section 127Section 139(1)Section 143(2)Section 153ASection 153CSection 2(22)(e)Section 250

that the addition under section 2(22)(e) of the Income Tax Act, 1961, despite the presence of seized material substantiating the nature of deemed dividend transactions and concluding that the addition was solely based on financial statements already submitted by the assessee.” 4. Brief facts of the case

Asst Commissioner of Income Tax, Central Circle -3, Thane vs. Arun Kumar Pillai, Bengaluru

In the result, the appeal filed by the Revenue is dismissed for statistical purpose

ITA 1940/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 May 2025AY 2015-16

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri. Nishchit GandhiFor Respondent: DR. K. R. Subhash (CIT DR)
Section 127Section 139(1)Section 143(2)Section 153ASection 153CSection 2(22)(e)Section 250

that the addition under section 2(22)(e) of the Income Tax Act, 1961, despite the presence of seized material substantiating the nature of deemed dividend transactions and concluding that the addition was solely based on financial statements already submitted by the assessee.” 4. Brief facts of the case

Vishal Datt, Jablpur vs. ACIT Circle 2(1), Jabalpur

In the result, appeals of the assessee are allowed for statistical purposes

ITA 78/JAB/2024[2017-18]Status: DisposedITAT Jabalpur21 May 2025AY 2017-18

Bench: Shri Kul Bharat & Shri, Nikhil Choudhary

For Appellant: Shri Sanjay Seth, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)

dismissed. It is requested kindly delete the addition made by AO. 2 AO has made addition of 15,77,156/- on account of deemed: dividend. It is submitted that assessee is one of the shareholder of Datt Real Infra Pvt. Ltd. from whom assessee firm is having business transaction. Assessee ... dismissed. It is requested kindly delete the addition made by AO. 2. AO has made addition of Rs.45,11,612/- on account of deemed dividend. It is submitted that assessee is one of the shareholder of Datt Real Infra Pvt Ltd from whom assessee firm is having business transaction. Assessee

Vishal Datt, Jabalpur vs. ACIT Circle2(1), Jabalpur

In the result, appeals of the assessee are allowed for statistical purposes

ITA 77/JAB/2024[2013-14]Status: DisposedITAT Jabalpur21 May 2025AY 2013-14

Bench: Shri Kul Bharat & Shri, Nikhil Choudhary

For Appellant: Shri Sanjay Seth, CAFor Respondent: Shri Alok Bhura, Sr. CIT(DR)

dismissed. It is requested kindly delete the addition made by AO. 2 AO has made addition of 15,77,156/- on account of deemed: dividend. It is submitted that assessee is one of the shareholder of Datt Real Infra Pvt. Ltd. from whom assessee firm is having business transaction. Assessee ... dismissed. It is requested kindly delete the addition made by AO. 2. AO has made addition of Rs.45,11,612/- on account of deemed dividend. It is submitted that assessee is one of the shareholder of Datt Real Infra Pvt Ltd from whom assessee firm is having business transaction. Assessee

Ayaj S. Dhumal, Mumbai vs. ITO - 26(2)(4), Mumbai

ITA 4519/MUM/2013[2006-07]Status: DisposedITAT Mumbai19 May 2025AY 2006-07

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2006-07 Ajay S. Dhumal, Ito-26(2)(4), 229/230, Arun Chambers, 2Nd Floor, Mumbai. Vs. Tardeo, Mumbai-400034. Pan No. Aacpd 7035 Q Appellant Respondent

For Appellant: Mr. Ram Krishn Kedia, Sr. DRFor Respondent: Mr. Piyush Chaturvedi
Section 143(1)Section 2(22)(e)

companies. both the companies. As such, the amount received was liable to As such, the amount received was liable to be treated as deemed dividend deemed dividend under section 2(22)(e) of the Act under section 2(22)(e) of the Act in the hands of the assesse ... Accordingly, he concluded that the said loan was liable to be taxed as d that the said loan was liable to be taxed as deemed dividend under eemed dividend under section 2(22)(e) in the hands of Mr. Dhumal section 2(22)(e) in the hands of Mr. Dhumal

Dy. C.I.T. Central Cir.-2(2), Nagpur vs. Shri Dharampal R.Agrawal, Nagpur

In the result, Revenue’s appeal stands dismissed

ITA 307/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 153A

business income as per 11. ` 3,43,000 para 15 Loan from Shree Agrawal Fin. Corp. treated as 12. ` 6,82,55,000 deemed dividend u/s 2(22)(e) as per para 16 Cash deposits with H.D.F.C. bank treated as ` 42,36,000 13. undisclosed income. As per para

A, C.I.T. Central Cir.- 2(2), Nagpur vs. Shri Dharampal R.Agrawal, Nagpur

ITA 293/NAG/2016[2008-09]Status: DisposedITAT Nagpur15 May 2025AY 2008-09

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

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 2(22)(e)Section 40Section 43B

facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting ... addition made on account of deemed dividend u/s 2(22)(e) of Rs. 8,75,36,654/-. 7. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of disallowance of depreciation

A, C.I.T. Central Cir.- 2(2), Nagpur vs. Shri Dharampal R.Agrawal, Nagpur

In the result, Revenue’s appeal being ITA no

ITA 292/NAG/2016[2007-08]Status: DisposedITAT Nagpur15 May 2025AY 2007-08

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

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 40Section 43B

facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting ... addition made on account of deemed dividend u/s 2(22)(e) of Rs. 8,75,36,654/-. 7. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of disallowance of depreciation

Dy. C.I.T. Central Cir2(2), Nagpur vs. M/S Shree Agrawal Coal India Pvt. Ltd., Nagpur

In the result, Revenue’s appeal being ITA no

ITA 23/NAG/2016[2008-09]Status: DisposedITAT Nagpur15 May 2025AY 2008-09

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

For Appellant: Shri Sachin V. LuthraFor Respondent: Shri Harshad S. Vengurlekar
Section 153ASection 40Section 43B

facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of deemed dividend u/s 2(22)(e) of Rs. 4,77,67,712/-. 6. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting ... addition made on account of deemed dividend u/s 2(22)(e) of Rs. 8,75,36,654/-. 7. On the facts and circumstances of the case, the learned CIT(A) has erred in deleting the addition made on account of disallowance of depreciation