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“Section 2(22)”

Section References (mined)Section 2Section 2(22)685 judgments

ARIMILLI RAMA KRISHNA,WEST GODAVARI DIST vs. ACIT, CIRCLE-1, RAJAHMUNDRY

ITA 639/VIZ/2025[2014-15]Status: DisposedITAT Visakhapatnam18 Mar 2026AY 2014-15

Bench: Shri Ravish Sood, Hon’Ble & Shri Omkareshwar Chidara, Hon’Ble

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 194CSection 194JSection 2(22)(e)Section 263

excess amount withdrawn by the assessee, i.e., up to the extent of the accumulated profits available with the company as “deemed dividend” under section 2(22)(e) of the Act and made an addition of the same in the hands of the assessee. Accordingly, the AO, vide his order passed ... ground has no meaning and no force and is not acceptable and is dismissed. 6.8 In the 7th ground the addition made under section 2(22)(e) of the Income Tax Act 1961 has been challenged. It has been stated that the appellant had offered his personal properties as collateral

SHREERAM CONSTRUCTIONS,BHOPAL vs. COMMISSIONER OF INCOME-TAX (APPEALS), DELHI

In the result the “Impugned order” is set aside as and by

ITA 481/IND/2025[2013-14]Status: DisposedITAT Indore27 Feb 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshishreeram Construction, Commissioner Of बनाम/ Shop No.2,New Shri Ram Income-Tax Vs. Parisar, Phase I Khajuri Kala, (Appeals) Bhopal, Bhopal (Pan:Abgfs5939P) (Appellant) (Respondent) Assessee By Shri Govind Rinwa, Ca Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 09.02.2026 Date Of Pronouncement 27.02.2026 आदेश/ O R D E R

Section 143(1)Section 143(3)Section 194CSection 2(22)Section 2(22)(e)Section 246ASection 250Section 253Section 37(1)Section 40

आयकरअपीलीयअिधकरण, इंदौर"ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND

BANGALORE UNION SERVICES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(2), CHENNAI

In the result, the appeal of the assessee is allowed

ITA 2483/CHNY/2025[2012-13]Status: DisposedITAT Chennai26 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate (by Virtual)For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 147Section 2(22)(e)

amounting to Rs.99,25,000/- and loan given to Mr. Sivaramakrishnan amounting to Rs.2,00,00,000/- as deemed dividend in terms of Section 2(22)(e) of the Act in the computation of taxable total income without assigning proper reasons and justification. 7. The NFAC, Delhi to appreciate that ... provisions of Section 2(22)(e) of the Act had no application to the present facts and in circumstances of the case, inasmuch ought to have appreciated that pre-requisite conditions required for invoking the provisions in Section 2(22)(e) of the Act were absent in the present case

AMAR IRON UDYOG PVT. LTD.,KOLKATA vs. DCIT, CC-3(3), KOLKATA

In the result, both the appeals of the assessee are allowed for\nstatistical purposes

ITA 2848/KOL/2025[2011-2012]Status: DisposedITAT Kolkata17 Feb 2026AY 2011-2012
Section 2(22)(e)Section 68

whereas the Id. CIT (A) while\npassing an appellate order wrongly extracted the facts of some\ndifferent assessee dealing with the issue of Section 2(22)(e) of the\nIncome-tax Act, 1961 and thus, confirming the addition by mentioning\nthe amount as ₹34,64,771/-. Therefore, this appears ... capital received, treating it as unexplained cash credit under Section 68. For ITA No. 2848/KOL/2025, the addition was confirmed by the AO under Section 2(22)(e).", "held": "In the first appeal, the Tribunal noted that the CIT(A) had erroneously extracted facts from a different case involving Section 2

AMAR IRON UDYOG PVT. LTD.,KOLKATA vs. D.C.I.T., CC - 3(3), KOLKATA

In the result, both the appeals of the assessee are allowed for\nstatistical purposes

ITA 2847/KOL/2025[2011-2012]Status: DisposedITAT Kolkata17 Feb 2026AY 2011-2012
Section 2(22)(e)Section 68

whereas the Id. CIT (A) while\npassing an appellate order wrongly extracted the facts of some\ndifferent assessee dealing with the issue of Section 2(22)(e) of the\nIncome-tax Act, 1961 and thus, confirming the addition by mentioning\nthe amount as ₹34,64,771/-. Therefore, this appears ... 2847/KOL/2025, the addition was for share capital received under Section 68. For ITA No. 2848/KOL/2025, the addition was under Section 2(22)(e) and the CIT(A) order was passed ex-parte.", "held": "In the first case, the CIT(A) wrongly extracted facts from a different case and confirmed

KISHOR CHANGYA PATIL,MUMBAI vs. ITO41(1)(2), MUMBAI

ITA 8032/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Feb 2026AY 2016-17
Section 143(2)Section 143(3)Section 2(22)(e)Section 250(4)

nsubmissions were made by the assessee, however the assessment was completed\n2\nITA No.8024/Mum/2025\nMr. Kailash Prakash Karamchandani\nwith the addition under section 2(22)(e) of the Act for Rs. 38,76,790/- and Rs.\n69,13,475/-.\n3.\nBeing aggrieved with the aforesaid addition assessee preferred the appeal ... dismissed the appeal in limine due to non-prosecution. The CIT(A)'s order stemmed from additions made by the Assessing Officer under section 2(22)(e) of the Income Tax Act for the assessment year 2014-15.", "held": "The Tribunal observed that the CIT(A) had not adjudicated

SAHARA INDIA LIMITED,LUCKNOW vs. THE ACIT.,, NEW DELHI

ITA 1243/DEL/2009[2003-04]Status: DisposedITAT Delhi10 Feb 2026AY 2003-04

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

ACIT, LUCKNOW vs. SAHARA INDIA LTD.,, LUCKNOW

ITA 78/LKW/2006[2000-01]Status: DisposedITAT Delhi10 Feb 2026AY 2000-01

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

ACIT, LUCKNOW vs. SAHARA INDIA LTD.,, LUCKNOW

ITA 46/LKW/2006[1998-99]Status: DisposedITAT Delhi10 Feb 2026AY 1998-99

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

ACIT, LUCKNOW vs. SAHARA INDIA LTD.,, LUCKNOW

ITA 45/LKW/2006[1997-98]Status: DisposedITAT Delhi10 Feb 2026AY 1997-98

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

ACIT, LUCKNOW vs. SAHARA INDIA LTD.,, LUCKNOW

ITA 127/LKW/2006[2001-02]Status: DisposedITAT Delhi10 Feb 2026AY 2001-02

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

SAHARA INDIA LTD.,,LUCKNOW vs. ACIT, LUCKNOW

ITA 898/LKW/2005[1996-97]Status: DisposedITAT Delhi10 Feb 2026AY 1996-97

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 1996-97 With Assessment Year: 2003-04 Sahara India Limited, Vs. Acit, Central Circle-I, I - Kapoorthala Complex, Lucknow Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent) With Ita No.45/Lkw/2006 Along With C.O. No.36/Lkw/2006 Assessment Year: 1997-98 With Ita No.46/Lkw/2006 Along With C.O. No.37/Lkw/2006 Assessment Year: 1998-99 With Ita No.78/Lkw/2006 Along With C.O. No.39/Lkw/2006 Assessment Year: 2000-01 With Ita No.127/Lkw/2006 Along With C.O. No.40/Lkw/2006 Assessment Year: 2001-02 Acit, Central Circle-I, Vs. Sahara India Limited, Lucknow I-Kapoorthala Complex, Aliganj, Lucknow Pan: Aadcs4402J (Appellant) (Respondent/Cross-Objector) Assessee By Sh. Percy Pardiwala, Sr. Advocate Sh. Devashish A Mehrotra, Ca Sh. Sarvesh Srivastava, Advocate Department By Ms. Monika Singh, Cit(Dr)

Section 143(3)Section 2(22)(e)

counsel submits at the outset that the assessee/appellant raises its sole substantive ground herein seeking to reverse both the lower authorities’ action invoking section 2(22)(e) deemed dividend addition of Rs.5 crores; in assessment order dated 19.03.1999 as concurred in the lower appellate discussion. 4. That being the case ... held 24.97% and 84.82% stock, respectively. This being the clinching factual position, we are of the considered view that the impugned statutory provision section 2(22)(e) could not have been invoked in the assessee’s case in both the lower proceedings in absence of it being the common shareholder

JHV CONSTRUCTION CO. PVT. LTD.,KOLKATA vs. D.C.I.T., CC - 2(2), KOLKATA, KOLKATA

In the result, the appeal filed by the assessee is partly allowed but the order of the Pr

ITA 1289/KOL/2024[2014-2015]Status: DisposedITAT Kolkata09 Feb 2026AY 2014-2015

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 132Section 143(3)Section 153ASection 2(22)(e)Section 263Section 68

ground that the unsecured loan received from M/s. Welcome Distilleries Pvt Ltd should have been treated as deemed dividend in terms of section 2(22)(e) of the Income Tax Act, 1961. Since no incriminating material was found in the course of the search and seizure operation carried ... common shareholder. Hence, such loan should have been treated as Deemed Dividend u/s. 2(22)(e) of the Income Tax Act, 1961. 5. Section 2(22)(e) of the Income Tax Act is reproduced as under: "2. In this Act, unless the context otherwise requires, (22) "dividend" includes

ACIT, NEW DELHI vs. SH. ATUL BANSAL, NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 2803/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanatul Bansal, Vs. Acit, Central Circle 16 Farm No. 22, The Green Rajokri Delhi. New Delhi – 110 038. (Pan: Agcpb1274F) Acit, Central Circle 16, Vs, Atul Bansal Delhi Farm No. 22, The Green Rajokri New Delhi – 110 038. (Pan: Agcpb1274F) Assessee By : None Revenue By : Sh. Jitender Singh, Cit Dr Date Of Hearing : 18.11.2025 Date Of Order : 06.02.2026 O R D E R

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR
Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

details are as under: 7. By referring to the above chart, the Assessing Officer directed the assessee to explain why the provisions of Section 2(22)(e) of the Act should not be invoked. The Assessing Officer proceeded to make impugned amount of Rs.71,08,35,311/- as deemed dividend ... appellant by the AO as highlighted in the remand report. The legal position with regard to the application of provision of section 2(22)(e) is as under: (e) any payment by a company, not being a company in which the public are substantially interested, of any sum (whether

SH. ATUL BANSAL,NEW DELHI vs. ACIT, NEW DELHI

In the result, grounds raised by the revenue are dismissed

ITA 2737/DEL/2017[2013-14]Status: DisposedITAT Delhi06 Feb 2026AY 2013-14

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahmanatul Bansal, Vs. Acit, Central Circle 16 Farm No. 22, The Green Rajokri Delhi. New Delhi – 110 038. (Pan: Agcpb1274F) Acit, Central Circle 16, Vs, Atul Bansal Delhi Farm No. 22, The Green Rajokri New Delhi – 110 038. (Pan: Agcpb1274F) Assessee By : None Revenue By : Sh. Jitender Singh, Cit Dr Date Of Hearing : 18.11.2025 Date Of Order : 06.02.2026 O R D E R

For Appellant: NoneFor Respondent: Sh. Jitender Singh, CIT DR
Section 143(1)Section 143(2)Section 14ASection 2(22)(e)Section 54Section 54B

details are as under: 7. By referring to the above chart, the Assessing Officer directed the assessee to explain why the provisions of Section 2(22)(e) of the Act should not be invoked. The Assessing Officer proceeded to make impugned amount of Rs.71,08,35,311/- as deemed dividend ... appellant by the AO as highlighted in the remand report. The legal position with regard to the application of provision of section 2(22)(e) is as under: (e) any payment by a company, not being a company in which the public are substantially interested, of any sum (whether

ANANG KUNJVIHARIBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-7(2)(1) (PREVIOUSLY DCIT, CIRCLE-1(1)(2)), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1156/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalincome-Tax Officer, Anang Kunjviharibhai Shah, Vs. Ward 7(2)(1), 1, Friends Colony, Sm Road, Vejalpur, Ahmedabad Ambawadi, Ahmedabad-380015 [Pan: Acups 2559 J] (Previously Dcit, Cir. 1(1)(2)) (Appellant) .. (Respondent) Appellant By: Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, Sr. DR
Section 2(22)(e)Section 250Section 80G

contrary to the facts of the case and the evidence on records. That the learned CIT(A) has misconstrued the provisions of section 2(22)(e) of the act. 3. That appellant respectfully submit that there is no loan given by the company which has resulted in benefit ... assessee’s own deposit lying with the company and does not constitute a loan or advance. The Ld. AR also submitted that section 2(22)(e) applies only when a company grants a loan or advance out of its accumulated profits to a shareholder, which results in a benefit flowing

INCOME TAX OFFICER, WARD - 3(1), PUNE, PUNE vs. SACHIN GOVIND APTE, PUNE

Accordingly, Grounds of appeal raised by the Revenue are dismissed

ITA 1720/PUN/2025[2013-14]Status: DisposedITAT Pune03 Feb 2026AY 2013-14

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1720/Pun/2025 निर्धारण वषा / Assessment Years: 2013-14 The Income Tax Officer, V Sachin Govind Apte, Ward-3(1), Pune. S. 759-63, Prabhat Road, Erandwana, Pune – 411004. Pan: Aavpa9458P Appellant/ Revenue Respondent /Assessee Assessee By Ms.Vaishnavi Badwe Revenue By Shri Amit Bobde - Cit(Dr) Date Of Hearing 16/12/2025 Date Of Pronouncement 03/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Revenue Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 15.05.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 30.03.2016. The Revenue Has Raised The Following Grounds Of Appeal : “1. Whether On The Facts & Circumstances Of The Case & In Law The Hon'Ble Cit (A) Was Justified In Deleting The Addition Of Rs.78,72,000/- Made Under Head Stcg & Disallowance Of Deduction U/S 54F Of The It. Act, 1961? 2. Whether On The Facts & Circumstances Of The Case & In Law The Hon‟Ble Cti (A) Was Justified In Deleting The Addition Of Rs.1,20,00,000/- Made On Account Of Deemed Dividend U/S Section 2(22)(E) Of The I.T. Act, 1961?

Section 143(3)Section 2(22)(e)Section 250Section 54F

justified in deleting the addition of Rs.1,20,00,000/- made on account of deemed dividend u/s Section 2(22)(e) of the I.T. Act, 1961? ITA No.1720/PUN/2025 [D] 3. Whether on the facts and in the circumstances of the case and in law, the Hon‟ble CIT(A) erred ... position that trade advances, which are in the nature of commercial transactions would not fall within the ambit of the word „advance‟ in section 2(22)(e) of the Act. Accordingly, henceforth, appeals may not be filed on this ground by Officers of the Department and those already filed

ARUNKUMAR JAYANTILAL MUCHHALA ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX , MUMBAI

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

ITA 5400/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Jan 2026AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

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

that the payer company does not possess "accumulated profits" at the beginning of the financial year 2005-06 and accordingly the provisions of section 2(22)(e) cannot be applied in absence of "accumulated profits" 3. Without prejudice to the above grounds, the CIT (A) has erred in confirming addition ... vide order dated 30.08.2011, determining total income at rs.48,61,170/- which included addition of Rs.35,79,937/- within the scope of section 2(22)(e). The assessee filed an appeal before the Ld. CIT(Appeals) but the same was dismissed. 5. Aggrieved, the assessee filed appeal before

ARUNKUMAR JAYANTILAL MUCHHALA ,MUMBAI vs. DY. COMMISSSIONER OF INCOME TAX , MUMBAI

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

ITA 5399/MUM/2025[2010-11]Status: DisposedITAT Mumbai27 Jan 2026AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

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

that the payer company does not possess "accumulated profits" at the beginning of the financial year 2005-06 and accordingly the provisions of section 2(22)(e) cannot be applied in absence of "accumulated profits" 3. Without prejudice to the above grounds, the CIT (A) has erred in confirming addition ... vide order dated 30.08.2011, determining total income at rs.48,61,170/- which included addition of Rs.35,79,937/- within the scope of section 2(22)(e). The assessee filed an appeal before the Ld. CIT(Appeals) but the same was dismissed. 5. Aggrieved, the assessee filed appeal before

ARUNKUMAR JAYANTILAL MUCHHALA ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, MUMBAI

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

ITA 5398/MUM/2025[2009-10]Status: DisposedITAT Mumbai27 Jan 2026AY 2009-10

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

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

that the payer company does not possess "accumulated profits" at the beginning of the financial year 2005-06 and accordingly the provisions of section 2(22)(e) cannot be applied in absence of "accumulated profits" 3. Without prejudice to the above grounds, the CIT (A) has erred in confirming addition ... vide order dated 30.08.2011, determining total income at rs.48,61,170/- which included addition of Rs.35,79,937/- within the scope of section 2(22)(e). The assessee filed an appeal before the Ld. CIT(Appeals) but the same was dismissed. 5. Aggrieved, the assessee filed appeal before

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