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“closely held company”

Losses & Set-offSection 79Section 79300 judgments

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

Leading authorities on closely held company

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.

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.

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.

(Refer: CIT v. C.P.Sarathy Mudaliar
83 ITR 170 · 1972 · Supreme Court
63
citing judgments

For the purpose of deemed dividend under section 2(22)(e) of the Income-tax Act, the term 'shareholder' refers exclusively to a registered shareholder of the company, and not a beneficial owner or non-shareholder.

CIT v. Madhur Housing and Development Company
401 ITR 152 · 2018 · Supreme Court
49
citing judgments

A loan or advance from a closely held company to a 'concern' where a common shareholder has a substantial interest is not a deemed dividend under Section 2(22)(e) for the 'concern' if it is not a shareholder of the lending company. Deemed dividend under Section 2(22)(e) is taxable only in the hands of the registered or beneficial shareholder.

CIT v. Mukundray K. Shah, Citation No.
160 Taxmann 276 · 2007 · Supreme Court
39
citing judgments

Section 2(22)(e) of the Income Tax Act, 1961, aims to prevent tax evasion by treating certain payments made by closely held companies to shareholders or their concerns as dividends.

PCIT v. BST Infratech Ltd.
161 Taxmann.com 668 · 2024 · High Court
32
citing judgments

When shares are issued at a premium, the genuineness of the transaction is paramount, not necessarily the source of the investor's funds. The court emphasizes verifying the transaction's authenticity, even if investor identity is established.

Judgments citing closely held company

DCIT Central Circle -2(2), Mumbai vs. Shri Viral Saraf Mittal, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 1843/MUM/2022[2018-19]Status: DisposedITAT Mumbai23 Feb 2024AY 2018-19

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit – Central Circle – 2(2) V. Viral Saraf Mittal Room No. 806, 8Th Floor 901/902, Capri Heights Old Cgo Annex Building Palli Hill, Bandra (W) M.K. Road, Mumbai - 400020 Mumbai - 400050 Pan: Azbps0317C (Appellant) (Respondent) Assessee Represented By : Shri Sidharth Kothari Department Represented By : Ms. Kavitha Kaushik

Section 10(38)Section 143(2)Section 68

fact that same was traded in NSE and receipts of sales routed through bank and company whose shares were sold was not a closely held company, no addition could be made as undisclosed income." 8.12. The Hon'ble Bombay High Court in the case of CIT vs Shyam R. Pawar

M/S. Brightstar Vincom Pvt.Ltd., 700007 vs. I.T.A, Ward-3(3), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 176/KOL/2023[2012-13]Status: DisposedITAT Kolkata21 Feb 2024AY 2012-13

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.176/Kol/2023 Assessment Year: 2012-13 M/S Brightstar Vincom Pvt. Ltd…..…......................…...……………....Appellant 18/1, 4Th Floor, Room No.48, M.D. Road, Burrabazar, Kolkata-700007. [Pan: Aadcb2082R] Vs. Ito, Ward-3(3), Kolkata........…..........................................…..…..... Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 14, 2023 Date Of Pronouncing The Order : February 21, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 30.01.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 142(1)Section 234Section 250Section 68

made the impugned additions. The relevant part of the order of the Assessing Officer is reproduced as under: “The assessee company is a closely held company in which public are not substantially interested. Keeping this in consideration, notice under section 131 were issued and sent to the assessee requiring

DCIT, Central Circle-2(2), Chennai vs. M/S.Minal Constractors and Builders Pvt Lit., Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 646/CHNY/2023[2021-23]Status: DisposedITAT Chennai21 Feb 2024AY 2021-23

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 139(1)Section 2(22)(e)

down three situations where deemed dividend arises in the hands of the shareholders. The first situation is where loan is advanced by a closely held company to a shareholder who holds not less than 10% of the voting power in the said company. The second situation is where loan ... advanced by a closely held company to a concern in which a shareholder of such company holding not less than 10% of the voting power has substantial interest in the concern. The third situation is where any payment is made by a closely held company on behalf

DCIT, Central Circle-2(2), Chennai vs. M/S. Meadow Infrastructure Pvt Lit., Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 645/CHNY/2023[2021-22]Status: DisposedITAT Chennai21 Feb 2024AY 2021-22

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 139(1)Section 2(22)(e)

down three situations where deemed dividend arises in the hands of the shareholders. The first situation is where loan is advanced by a closely held company to a shareholder who holds not less than 10% of the voting power in the said company. The second situation is where loan ... advanced by a closely held company to a concern in which a shareholder of such company holding not less than 10% of the voting power has substantial interest in the concern. The third situation is where any payment is made by a closely held company on behalf

DCIT, Central Circle-2(2), Chennai vs. M/S.Mac Quality Builders Pvt Lit., Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 644/CHNY/2023[2021-22]Status: DisposedITAT Chennai21 Feb 2024AY 2021-22

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 139(1)Section 2(22)(e)

down three situations where deemed dividend arises in the hands of the shareholders. The first situation is where loan is advanced by a closely held company to a shareholder who holds not less than 10% of the voting power in the said company. The second situation is where loan ... advanced by a closely held company to a concern in which a shareholder of such company holding not less than 10% of the voting power has substantial interest in the concern. The third situation is where any payment is made by a closely held company on behalf

DCIT, Central Circle-2(2), Chennai vs. M/S. Mukilanstructurals Pvt Lit., Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 643/CHNY/2023[2021-22]Status: DisposedITAT Chennai21 Feb 2024AY 2021-22

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 139(1)Section 2(22)(e)

down three situations where deemed dividend arises in the hands of the shareholders. The first situation is where loan is advanced by a closely held company to a shareholder who holds not less than 10% of the voting power in the said company. The second situation is where loan ... advanced by a closely held company to a concern in which a shareholder of such company holding not less than 10% of the voting power has substantial interest in the concern. The third situation is where any payment is made by a closely held company on behalf

DCIT, Central Circle-2(2), Chennai vs. M/S. Mukunda Land Developers Pvt Lit., Chennai

In the result, all the appeals filed by the Revenue are dismissed

ITA 642/CHNY/2023[2021-22]Status: DisposedITAT Chennai21 Feb 2024AY 2021-22

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 139(1)Section 2(22)(e)

down three situations where deemed dividend arises in the hands of the shareholders. The first situation is where loan is advanced by a closely held company to a shareholder who holds not less than 10% of the voting power in the said company. The second situation is where loan ... advanced by a closely held company to a concern in which a shareholder of such company holding not less than 10% of the voting power has substantial interest in the concern. The third situation is where any payment is made by a closely held company on behalf

Lovely Promoters Private Limited, Kolkata vs. ACIT, Central Circle, Ajmer

In the result, the appeal filed by the assessee is allowed

ITA 770/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Feb 2024AY 2013-14

Bench: him regarding non mentioning of Document Identification Number (DIN) in the body of the order u/s. 127 of the Act dated 08-09-2021 and various other technical pleas raised in grounds of appeal regarding validity of notice u/s. 148 of the Act, thereby appellate order passed by the CIT(A) is non-speaking order and deserves to be quashed. 4. On the facts and in circumstances of the case and in law, the AO erred in issuing notice u/s. 148 of the Act as it was a search related case u/s. 132 r/w

For Appellant: Shri Mayank Taparia (Adv.)For Respondent: Shri A.S. Nehra (Addl.CIT) a
Section 127Section 127(1)Section 132Section 147Section 148Section 148ASection 151Section 153C

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

D.C.I.T., CC-1(3), Kolkata vs. M/S. Navin Construction & Credit Pvt. Ltd., Kolkata

In the result, appeal of the revenue is dismissed and cross- objection of the assessee is allowed

ITA 580/KOL/2022[2015-2016]Status: DisposedITAT Kolkata31 Jan 2024AY 2015-2016

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri Akkal Dudhewala, A/RFor Respondent: Shri Abhijit Kundu, CIT, D/R
Section 133(6)Section 14ASection 250Section 35Section 35(1)Section 68

this context, it is pertinent to refer to the proviso to section 68, which provides that in cases where assessee is a closely held company, and any sum is found credited by way of share capital, share application money, share premium etc., the "source of source of such credits

Aakruti Ketan Mehta, Mumbai vs. ITO, Ward-35(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 53/MUM/2023[2014-2015]Status: DisposedITAT Mumbai31 Jan 2024AY 2014-2015

Bench: SHRI AMIT SHUKLA (Judicial Member), MS. PADMAVATHY S (Accountant Member)

Section 10(38)Section 131Section 143(3)Section 68

equity shares of Conart Traders Ltd being held by Santoshima Tradelinks Ltd. on 27/11/2011 for Rs.11,00,000/- to market from one closely held company at Rs.20/- per share. Shares were purchased through account payee cheques paid on 07/09/2011. Share certificates regarding transfer of shares in the name

Lakshmi Mendalu Narayan Rao Naidu, Mumbai vs. National Faceless Assessment Centre (NFAC), Delhi

In the result, all the three appeals of the assessee are treated as allowed

ITA 3100/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 Jan 2024AY 2013-14

Bench: Shri B R Baskaran, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Manoj Kumar Sinha
Section 144Section 2(22)(e)Section 250Section 69C

made as deemed dividend u/s 2(22)(e) of the Act. According to the AO, the assessee is a director in a closely held company named M/s Bhddheshwar Estates P Ltd and during the year under consideration, she has taken advance of Rs.14,85,000/-, besides salary of Rs.1 ... that the provisions of sec.2(22)(e) of the Act would get attracted only when the assessee is holding substantial interest in the closely held company as a shareholder, i.e., the provisions are not attracted on the basis of holding of directorship. Admittedly, the shareholding pattern of above said company

ITO, Ward-3(1)(3), Bangalore, Koramangala vs. Irunway India Pvt Ltd, Banaglore

ITA 676/BANG/2023[2014-15]Status: DisposedITAT Bangalore24 Jan 2024AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section 147Section 148Section 148ASection 56Section 56(2)(viib)

made by Assessing Officer in assessment order by invoking provisions of section 56(2)(viib) wherein it is mentioned that where a closely held company issues its shares at a price which is more than its fair market value then the amount received in excess of fair market value

DCIT, Central Circle-13, New Delhi vs. Nishit Capinvest P.Ltd, New Delhi

ITA 1312/DEL/2023[2016-17]Status: DisposedITAT Delhi04 Jan 2024AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Anubhav Sharma

Section 143(3)Section 68

Delhi, hereinafter referred to as the “AO”). 2 2. The facts in brief are the assessee in this case is a closely held company, engaged in the business of making investments. During the instant year it has raised share capital from Directors of the assessee company and their relatives when ... perused and examined by me. It is found as under: I. All the four subscribers of the assessee company which is an unlisted closely held company are either the existing shareholders or directors or relatives of the directors. II. The entire amount of subscription has been received by account payee

DCIT, Central Circle, Ghaziabad vs. Ajay Kumar, Meerut

ITA 594/DEL/2022[2017-18]Status: HeardITAT Delhi29 Dec 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 406/DEL/2022[2018-19]Status: HeardITAT Delhi29 Dec 2023AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 405/DEL/2022[2017-18]Status: HeardITAT Delhi29 Dec 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

Ajay Kumar, Meerut vs. DCIT, CC, Ghaziabad

ITA 404/DEL/2022[2016-17]Status: HeardITAT Delhi29 Dec 2023AY 2016-17

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharma

For Appellant: Shri Ajay Wadhwa, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 119Section 143(3)

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

Vayas Multi Trading Pvt Ltd, New Delhi vs. ACIT, Central Circle-14, New Delhi

The appeal is allowed as above

ITA 2295/DEL/2022[2012-13]Status: DisposedITAT Delhi29 Dec 2023AY 2012-13

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2012-13 Vayas Multi Trading Pvt. Ltd., Vs Acit, Ajay Kanjhlia & Associates, Central Circle-14, Lgf, The Statesman House, New Delhi. Barakhamba Road, New Delhi – 110 001. Pan: Aabcl1268K (Appellant) (Respondent) Assessee By : Shri C.S. Anand, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 12.12.2023 Date Of Pronouncement : .12.2023 Order Per Anubhav Sharma, Jm:

For Appellant: Shri C.S. Anand, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 119Section 143(3)

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1529/DEL/2021[2018-2019]Status: DisposedITAT Delhi29 Dec 2023AY 2018-2019

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under

DCIT, Central Circle-25, New Delhi vs. Sunil Aggarwal, Faridabad

ITA 1528/DEL/2021[2017-2018]Status: DisposedITAT Delhi29 Dec 2023AY 2017-2018

Bench: Sh. G.S. Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 119

Finance Act, 1955 with effect from April 1, 1955. These two sections provided that any payment made by a closely held company to its shareholders by way of advance or loan to the extent to which the company possesses accumulated profits shall be treated as dividend taxable under