M/S G G OILS & FATS PVT.LTD ,BATHINDA vs. DEPUTY COMMISSIONER OF INCOME TAX, BATHINDA
In the result, the assessee’s appeal is dismissed
ITA 508/ASR/2017[2014-15]Status: DisposedITAT Amritsar05 Jul 2019AY 2014-15
Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi. T. A. No. 508/Asr/2017 Assessment Year: 2014-15
For Appellant: Sh. P. N. Arora &For Respondent: Sh. Charan Dass (D.R.)
Section 143(3)Section 2(18)Section 2(22)(e)Section 56
Section 2(22)(e), it was argued therein, should be read down inasmuch as it carried an irrebuttable presumption of a loan or advance to a substantial shareholder being a distribution of profit and, thus, dividend thereto, by definition, by a company
(in which public is not substantially interested). It worked unfairly on those repaying the loan as against